Smith, Chris B From: Sent: To: Subject: Page 1 of 465 Francis D. Slider Wednesday, July 27, 2016 2:45 PM DEP Comments re: Water Quality Standards Laura Cooper, Dear Ms. Cooper: As a lifelong West Virginian, I would like to thank you for the opportunity to comment. Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Francis D. Slider fslider@frontier.com 1 Page 2 of 465 239 Fluharty Rd WV, West Virginia 26149 Smith, Chris B From: Sent: To: Subject: Page 3 of 465 Leigh Anne Keener Wednesday, July 27, 2016 11:48 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water.This is unacceptable! Water is life and it seems that today, that fact is overlooked. Think of your grandchildren. Google "China Pollution" and click on images. Then think when you review what industry has planned for us. Humans are supposed to be better than this Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. 1 Page 4 of 465 Thank you for the opportunity to comment. Leigh Anne Keener lakeener@frontier.com 76 McCartney Ave Morgantown, West Virginia 26505 2 Page 5 of 465 Smith, Chris B From: Sent: To: Subject: Lori Rose Wednesday, July 27, 2016 10:18 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Lori Rose fishnleo6969@yahoo.com 1 Page 6 of 465 461 19th St. Dunbar, West Virginia 25064 Page 7 of 465 Smith, Chris B From: Sent: To: Subject: Autumn Long Wednesday, July 27, 2016 8:47 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Autumn Long autumnlong11@gmail.com 1 Page 8 of 465 2127 Big Elk Rd Wallace, 26448 Page 9 of 465 Smith, Chris B From: Sent: To: Subject: Ellen Mueller Wednesday, July 27, 2016 8:23 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Ellen Mueller emueller9@hotmail.com 1 Page 10 of 465 21 Dr Buckhannon, West Virginia 26201 Page 11 of 465 Smith, Chris B From: Sent: To: Subject: Carli Maereneck Wednesday, July 27, 2016 8:13 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Carli Maereneck cmareneck@yahoo.com 1 Page 12 of 465 1394 Sweet Springs Valley Sweet Springs, West Virginia 24941 Page 13 of 465 Smith, Chris B From: Sent: To: Subject: Nori Onishi Wednesday, July 27, 2016 8:05 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Nori Onishi komushio@hotmail.com 1 Page 14 of 465 252 highland ave Morgantown, West Virginia 26505 Smith, Chris B From: Sent: To: Subject: Page 15 of 465 claire flanagan Wednesday, July 27, 2016 8:02 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, I have been a visitor to the Greenbrier Valley county seat of Lewisburg for the past twentyfive (25) years, spending months at a time living, shopping, eating, meeting, greeting, touring, studying, hiking, driving, swimming, rafting: anything that informs my soul through your special citizens and your natural treasures. I promote West Virginia as the most magnificent sets of mountains on this continent. I appreciate that this land is as it was going back generations. Let's honor our nation's heritage and let us keep these waters clean, clear and free of unnecessary chemicals. Let's do our ancestors proud. Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority 1 Page 16 of 465 watersheds. Thank you for the opportunity to comment. claire flanagan claireflanagan1@comcast.net 1688 Council Bluff Drive Atlanta, Georgia 30345 2 Page 17 of 465 Smith, Chris B From: Sent: To: Subject: Carol Sheffield Wednesday, July 27, 2016 7:23 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Carol Sheffield deepwoodell@wildblue.net 1 Page 18 of 465 297 Upper Childers Run Buckhannon, West Virginia 26201 Smith, Chris B From: Sent: To: Subject: Page 19 of 465 Jack Holmes Wednesday, July 27, 2016 7:10 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Jack Holmes catso56@aol.com 1 Page 20 of 465 n/a n/a, West Virginia 26554 Page 21 of 465 Smith, Chris B From: Sent: To: Subject: Tracy Asbury Wednesday, July 27, 2016 6:33 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Tracy Asbury tracyasbury99@gmail.com 1 Page 22 of 465 PO Box 535 White Sulphur Springs, West Virginia 24986 Smith, Chris B From: Sent: To: Subject: Page 23 of 465 john brady Wednesday, July 27, 2016 5:49 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. john brady jkbrady@mac.com 1 Page 24 of 465 77 singletree drive shepherdstown, West Virginia 25443 Page 25 of 465 Smith, Chris B From: Sent: To: Subject: Barbara Humes Wednesday, July 27, 2016 5:33 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Barbara Humes bhumes1@comcast.net 1 Page 26 of 465 PO Box 1186 Harpers Ferry, West Virginia 25425 Page 27 of 465 Smith, Chris B From: Sent: To: Subject: Julie Martin Wednesday, July 27, 2016 5:18 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Julie Martin julamartin10@gmail.com 1 Page 28 of 465 107 1st Ave Frederic, Wisconsin 54837 Page 29 of 465 Smith, Chris B From: Sent: To: Subject: Erik Melear Wednesday, July 27, 2016 4:34 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Erik Melear h20eng@hotmail.com 1 Page 30 of 465 4008 Maguire Boulevard Orlando, Florida 32803 Page 31 of 465 Smith, Chris B From: Sent: To: Subject: Christopher Craig Wednesday, July 27, 2016 4:18 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Christopher Craig ccraig@laurellodge.com 1 Page 32 of 465 PO Box 1011 Harpers Ferry, Colorado 25425-1011 Smith, Chris B From: Sent: To: Subject: Page 33 of 465 Rachel Zorger Wednesday, July 27, 2016 4:11 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, As a practicing physician in rural WV, I strongly believe that environmental factors play a large role in long term health of people today and future generations. Water quality is of utmost importance for health and recreation for our people and our state. Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. 1 Page 34 of 465 Thank you for the opportunity to comment. Rachel Zorger rszorger@gmail.com 30 Boyd St Elkins, West Virginia 26241 2 Page 35 of 465 Smith, Chris B From: Sent: To: Subject: Patricia McNaull Wednesday, July 27, 2016 3:55 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Patricia McNaull trishmcnaull@yahoo.com 1 Page 36 of 465 131 Drennen Ridge Rd Marlinton, West Virginia 24954 Page 37 of 465 Smith, Chris B From: Sent: To: Subject: William Turner Wednesday, July 27, 2016 3:42 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. William Turner ichthyocentric@hotmail.com 1 Page 38 of 465 531 Church St. Lewisburg, West Virginia 24901 Smith, Chris B From: Sent: To: Subject: Page 39 of 465 Charles Marsh Wednesday, July 27, 2016 3:25 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators. I appreciate the exposure E. Coli has recently received worldwide, but it is far from the only water born disease. This is especially true in rural areas. Increase sampling frequency to measure average values for more high-risk and priority watersheds as necessary. Thank you for the opportunity to comment. 1 Page 40 of 465 Charles Marsh marshbc@aol.com 138 Old Mill Manor Trail Berkeley Springs, WV, West Virginia 25411 2 Page 41 of 465 Smith, Chris B From: Sent: To: Subject: Robert A. Mertz Wednesday, July 27, 2016 3:19 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, I am a retired science teacher. I spent thirty one years teaching Biology, Environmental Earth Science and Wildlife Management classes in the public school systems of three states. My education was first as a Biologist, teaching came later. I have a Master of Science degree in Biology. As a biologist I am concerned with the effects our large human population is having on the sustainability of our Earth's life support systems. Although there are some impressive natural systems that help to stabilize the living environment on our planet, there are limits to how much abuse these systems can withstand. The fossil records show that in the past there have been several major disruptions of these systems. Today the biggest threat to our space ship Earth comes from the activities of us humans. Our continued population growth combined with the crazy notion that there must always be an expanding economy is a surefired prescription for disaster. Misguided economic policies are in direct conflict with the natural limits of Earth. Our finite planet can not provide unlimited resources to allow us to continue on the path we are on. We must make decisions based on sound ecological principles if we are to bequeath our children and grandchildren with a place to live that is both sustainable and interesting. It will be a tragedy of monstrous proportions if our shortsighted way of making decisions degrades the world that our children inherent. The wonderful diversity of living creatures and wild unspoiled natural places must be preserved for them. It seems that we are unaware that the wild natural places are the ultimate infrastructure of the planet. Our present economic systems of continued growth are nothing more than a Ponzi scheme in which our decedents will be left with nothing of value. I am writing today to request that you help address one of the issues that will affect future generations, including our two sons and our wonderful seven year old granddaughter. Please 1 Page 42 of 465 try to throw off the short term considerations and take action that will address the long term welfare of humankind. The welfare of all of our children are depending on us. Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Robert A. Mertz no1ramertz@gmail.com 1205 Mulberry Ridge West Virginia, West Virginia 25276-8561 2 Page 43 of 465 Smith, Chris B From: Sent: To: Subject: Martha Mullett Wednesday, July 27, 2016 3:17 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Martha Mullett martha.mullett@gmail.com 1 Page 44 of 465 Lakeside Estates Morgantown, West Virginia 26508 Page 45 of 465 Smith, Chris B From: Sent: To: Subject: Joseph Wenzel Wednesday, July 27, 2016 3:00 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Joseph Wenzel josephwenzel@msn.com 1 Page 46 of 465 93 Midwest Ave. Lake Elmo, Minnesota 55042 Page 47 of 465 Smith, Chris B From: Sent: To: Subject: James Hansen Wednesday, July 27, 2016 3:00 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. James Hansen seinseifen@yahoo.com 1 Page 48 of 465 802 Lake Ave. Wilmette, Illinois 60091 Page 49 of 465 Smith, Chris B From: Sent: To: Subject: Michael Moore Wednesday, July 27, 2016 2:34 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, We need Water Quality Standards that protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Please keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Michael Moore moorem@marshall.edu 1 Page 50 of 465 RR2, Box 189 Ona, WV, West Virginia 25545 Smith, Chris B From: Sent: To: Subject: Page 51 of 465 Vivian Stockman Wednesday, July 27, 2016 2:17 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Vivian Stockman viv@spectrumz.com 1 Page 52 of 465 249 Millstone Run Spencer, West Virginia 25276 Smith, Chris B From: Sent: To: Subject: Page 53 of 465 Deborah Hancock Wednesday, July 27, 2016 2:08 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water protection has got to be one of the highest priorities with public policy. We are counting on you to make sure the protections get and stay strong NOT to allow more laxity for polluters. Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. 1 Page 54 of 465 Thank you for the opportunity to comment. Deborah Hancock Deborah Hancock deborah@manicmeltdown.com 44 Little Queen Road Clendenin, West Virginia 25045 2 Page 55 of 465 Smith, Chris B From: Sent: To: Subject: Judith Smith Wednesday, July 27, 2016 2:08 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Judith Smith axisdance@comcast.net 1 Page 56 of 465 2712 Grande Vista Ave Oakland, California 94601 Smith, Chris B From: Sent: To: Subject: Page 57 of 465 susan vanmeter Wednesday, July 27, 2016 1:57 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. susan vanmeter wolfmoon@citlink.net 1 Page 58 of 465 rr1 Paw Paw, West Virginia 25434 Smith, Chris B From: Sent: To: Subject: Page 59 of 465 Ilene Sussman Wednesday, July 27, 2016 1:56 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Ilene Sussman zimajunkie@aol.com 1 Page 60 of 465 235 Adams Street, 7F Brookyn, New York 11201 Smith, Chris B From: Sent: To: Subject: Page 61 of 465 David Wooddell Wednesday, July 27, 2016 1:46 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, My family has owned the Wooddell Farm on top of Allegheny Mountain, Pocahontas County since the 1870s. We maintain it in a very good ecological balance, and keep the waters that run off our mountain clean enough for native trout. Your department is charged with keeping the waters of West Virginia clean. You must protect the water, for it is not replaceable. Once water is polluted, especially with fracking waste, it is gone forever. Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial 1 Page 62 of 465 indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. - David W. Wooddell, land owner in Pocahontas County David Wooddell dwooddell@gmail.com 4924 Leeds Ave Baltimore, Maryland 21227 2 Page 63 of 465 Smith, Chris B From: Sent: To: Subject: Kat Cooper Wednesday, July 27, 2016 1:08 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Kat Cooper katcooper304@yahoo.com 1 Page 64 of 465 2928 Lake Rd Hedgesville, West Virginia 25427 Smith, Chris B From: Sent: To: Subject: Page 65 of 465 Rhonda Marrone Wednesday, July 27, 2016 1:45 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Rhonda Marrone rmm164@yahoo.com 1 Page 66 of 465 939 Somerset Dr. wv, West Virginia 25302 Page 67 of 465 Smith, Chris B From: Sent: To: Subject: Karen Fedorov Wednesday, July 27, 2016 1:33 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Karen Fedorov karen.fedorov@gmail.com 1 Page 68 of 465 8044 Tackett Ln Bealeton, VA, Virginia 22712-7844 Smith, Chris B From: Sent: To: Subject: Page 69 of 465 Mary L. Wednesday, July 27, 2016 1:33 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Mary L. mar3336@citynet.net 1 Page 70 of 465 Lee St. Charleston, West Virginia 25323 Page 71 of 465 Smith, Chris B From: Sent: To: Subject: Kevin Eich Wednesday, July 27, 2016 1:30 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Kevin Eich shred_head@hotmail.com 1 Page 72 of 465 113 Arnold drive Middletown Ohio 45044 Smith, Chris B From: Sent: To: Subject: Page 73 of 465 Kelly Irwin Wednesday, July 27, 2016 1:26 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Kelly Irwin kellyir01@yahoo.com 1 Page 74 of 465 352 Valley Brook Rd #01 Ambler, 19002 Page 75 of 465 Smith, Chris B From: Sent: To: Subject: Dave Harshbarger Wednesday, July 27, 2016 1:24 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, For the sake of our economic future with tourism (clean water is at the heart of outdoor based tourism), our children, and our legacy, we need to protect our headwaters and waterways. We need to be the people on watch, not the ones who need to be watched for lessening quality. Please support protecting water quality standards. thank you, Dave Dave Harshbarger harshbargerd@wvumedicine.org 1009 Vandalia Road Morgantown, West Virginia 26501 1 Smith, Chris B From: Sent: To: Subject: Page 76 of 465 Jan Darrah Wednesday, July 27, 2016 1:21 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, I frequently kayak and swim in our local rivers. Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Jan Darrah jldarrah@aol.com 1 Page 77 of 465 HC 77 Box 352 Hinton, West Virginia 25951 Smith, Chris B From: Sent: To: Subject: Page 78 of 465 Robert Gall Wednesday, July 27, 2016 1:17 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Robert Gall rgall17@comcast.net 1 Page 79 of 465 17 Damian Road Wheeling, West Virginia 26003 Page 80 of 465 Smith, Chris B From: Sent: To: Subject: Nathan Justice Wednesday, July 27, 2016 1:16 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Nathan Justice brookiebumwv@gmail.cim 1 Page 81 of 465 31 Barrcut Rd. Spencer, West Virginia 25276 Page 82 of 465 Smith, Chris B From: Sent: To: Subject: Steven Vogel Wednesday, July 27, 2016 1:09 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you very much for this opportunity to comment. Steven Vogel steven.j.vogel@earthlink.net 1 Page 83 of 465 449 Hampton Court Falls Church, VA, Virginia 22046-4121 Smith, Chris B From: Sent: To: Subject: Page 84 of 465 Jeff Witten Wednesday, July 27, 2016 1:06 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Jeff Witten JBWitten@aol.com 1 Page 85 of 465 2409 Lacewood Dr. Columbia, Missouri 65201 Page 86 of 465 Smith, Chris B From: Sent: To: Subject: Charles Brabec Wednesday, July 27, 2016 1:02 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Charles Brabec chuck@thebrabecs.com 1 Page 87 of 465 267 Ridgelawn Road Canvas, West Virginia 26662 Page 88 of 465 Smith, Chris B From: Sent: To: Subject: Sue Julian Wednesday, July 27, 2016 1:02 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Sue Julian suejulian@suddenlink.net 1 Page 89 of 465 PO Box 677 Pinch, West Virginia 25156 Smith, Chris B From: Sent: To: Subject: Page 90 of 465 Emily Keener Wednesday, July 27, 2016 11:55 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Emily Keener splishims@gmail.com 1 Page 91 of 465 76 McCartney Avenue Morgantown, West Virginia 26505 Smith, Chris B From: Sent: To: Subject: Page 92 of 465 Jody Ross Thursday, July 28, 2016 8:56 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Jody Ross jody0660@gmail.com 1 Page 93 of 465 2208 Donald Ave Huntington, West Virginia 25701 Smith, Chris B From: Sent: To: Subject: Page 94 of 465 Cody Jones Thursday, July 28, 2016 7:10 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. I would also like to propose stricter regulation regarding waste water injection; that it be made illegal in the state as a protection for the health and wellbeing of our citizens who should be able to enjoy the right to clean spring water sourced from their own backyards. Maintaining 1 Page 95 of 465 clean water, our most valuable resource is the best investment we can make for the future of West Virginia and for the environment. I live in Ona and have my water pumped to me via American waters, I then spend extra money just to ensure that I have clean spring water free of chlorine, fluoride and whatever else that could be in the public water. Thank you for the opportunity to comment. Cody Jones jones756@marshall.edu 3 Country Glen Drive Ona, West Virginia 25545 2 Page 96 of 465 Smith, Chris B From: Sent: To: Subject: Diana Greenhalgh Thursday, July 28, 2016 6:50 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Diana Greenhalgh diana12759@gmail.com 1 Page 97 of 465 2051 Red Lick Road New Milton, West Virginia 26411 Smith, Chris B From: Sent: To: Subject: Page 98 of 465 Robert Stanley Thursday, July 28, 2016 6:01 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. I hope the WVDEP will apply and maintain strict standards in order to protect the health of all citizens. 1 Page 99 of 465 Robert Stanley robert-stanley@mocs.utc.edu PO Box 126 St. Marys, Colorado 26170-0126 2 Smith, Chris B From: Sent: To: Subject: Page 100 of 465 Gary Parker Thursday, July 28, 2016 4:33 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Also...who wants lax standards...could it be industry...I say no to lax standards...would you want to drink a cold glass filled with carcinogens? Would you want to go to a cancer treatment center and receive chemotherapy? I think not! Thank you for the opportunity to comment. 1 Page 101 of 465 Gary Parker icelightning777@yahoo.com 144 Rock Ridge Lane Charmco, West Virginia 25958 2 Smith, Chris B From: Sent: To: Subject: Page 102 of 465 Kathryn Hawbaker Thursday, July 28, 2016 12:43 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. I am concerned about strong water standards to protect human health and environmental safety for the present and future. Thank-you for your attention and care. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. 1 Hawbaker revkatgreen@gmail.com 650 Ferncliff Dr. Marietta, Ohio 45750 Page 103 of 465 Smith, Chris B From: Sent: To: Subject: Page 104 of 465 Cynthia Ellis Thursday, July 28, 2016 11:55 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. I do so as a survivor of the 2014 water crisis and as someone who felt compelled to invest in a drilled well as a consequence. Yet I still would 1 Page 105 of 465 like to promote and rely upon a local water system. Please do what you can to make it a good one. Cynthia Ellis cdellis@wildblue.net 3114 Steel Ridge Rd Red House, West Virginia 25168 2 Page 106 of 465 Smith, Chris B From: Sent: To: Subject: Ciera Pennington Thursday, July 28, 2016 10:21 AM DEP Comments Water Quality Standards Laura Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Ciera Pennington cnpennington17@gmail.com 1 Page 107 of 465 1210 Garvin Avenue Charleston, West Virginia 25302 Page 108 of 465 Smith, Chris B From: Sent: To: Subject: Cassie Moats Thursday, July 28, 2016 9:42 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Cassie Moats cassmoats@gmail.com 1 Page 109 of 465 412 Hunter Ridge Rd. Crawford, West Virginia 26343 Smith, Chris B From: Sent: To: Subject: Page 110 of 465 JB Witten Thursday, July 28, 2016 9:22 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. JB Witten JBWitten@aol.com 1 Page 111 of 465 578 Faulkner Rd. Rt 1 Box 113 Elkins, West Virginia 26241 -9713 Page 112 of 465 Smith, Chris B From: Sent: To: Subject: Garth Lindley Thursday, July 28, 2016 9:07 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Garth Lindley lindleyjunk@yahoo.com 1 Page 113 of 465 3215 Bermuda Ave #22 Davis, California 95616 Page 114 of 465 Smith, Chris B From: Sent: To: Subject: Bert Lustig Thursday, July 28, 2016 8:06 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Bert Lustig buybook@earthlink.net 1 Page 115 of 465 3476 Mauzy Rd BerkeleySprings, West Virginia 25411 Smith, Chris B From: Sent: To: Subject: Page 116 of 465 Danette Brandy-Condon Thursday, July 28, 2016 7:27 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. I am a solar powered organic homesteader. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Please protect our water from pollution! 1 Page 117 of 465 Danette Brandy-Condon danettecondon@yahoo.com 7958 Lobelia Rd Hillsboro, West Virginia 24946 2 Page 118 of 465 Smith, Chris B From: Sent: To: Subject: Edward Savage Thursday, July 28, 2016 9:08 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Edward Savage nedsavage@gmail.com 1 Page 119 of 465 228 Richfield Ave. Salem, Virginia 24153 Page 120 of 465 Smith, Chris B From: Sent: To: Subject: paul e alloway Friday, July 29, 2016 8:56 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. paul e alloway pealloway@gmail.com 1 Page 121 of 465 151 Wood St Buckhannon, West Virginia 26201 Smith, Chris B From: Sent: To: Subject: Page 122 of 465 John Brewer Friday, July 29, 2016 3:57 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. John Brewer brwrj1@msn.com 1 Page 123 of 465 409 Aurora Street Marietta, Ohio 45750 Smith, Chris B From: Sent: To: Subject: Page 124 of 465 Mark Redd Friday, July 29, 2016 3:27 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Mark Redd usredds@gmail.com 1 Page 125 of 465 513 Tupper Street Marietta, Ohio 45750 Smith, Chris B From: Sent: To: Subject: Page 126 of 465 Stacey Wolfe Friday, July 29, 2016 3:12 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Stacey Wolfe narpet7@aol.com 1 Page 127 of 465 8225 Bodkin Ave Lake Shore, Maryland 21122 Page 128 of 465 Smith, Chris B From: Sent: To: Subject: Pamela Ellis Friday, July 29, 2016 10:51 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permits must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Pamela Ellis dr.pamelaellis@gmail.com 1 Page 129 of 465 122 Glory Ridge Place Kearneysville, West Virginia 25430 Page 130 of 465 Smith, Chris B From: Sent: To: Subject: Debbie Royalty Friday, July 29, 2016 9:17 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Debbie Royalty dar.royalty@gmail.com 1 Page 131 of 465 199 Brannon Ln Charles Town, West Virginia 25414 Smith, Chris B From: Sent: To: Subject: Page 132 of 465 Jeff Iliff Friday, July 29, 2016 8:50 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, As a member of two watershed associations I am concerned with keeping our water quality standards as strict as reasonably possible. Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. 1 Page 133 of 465 Jeff Iliff pfpjeff@gmail.com 21 Riggs LN Berkeley Springs WV, West Virginia 25411 2 Page 134 of 465 Smith, Chris B From: Sent: To: Subject: Niris Bharathae Friday, July 29, 2016 8:34 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, The changes proposed by WVDEP to the Water Quality Standards are a clear indication of collusion between your department and fracking interests who seek easy access to in-state resources. This is counter to the will of the people and is already perceived as a betrayal. West Virginians have a long memory and will not forget who fought for their rights nor those who shrank against the corporations. My hope is that you will do the right thing and cease your attempt to contravene the Water Quality Standards. Thank you for the opportunity to comment. Niris Bharathae nrb@wsims.com P.O.Box 229 Alderson, West Virginia 24910 1 Page 135 of 465 Smith, Chris B From: Sent: To: Subject: Nicole Casebolt Friday, July 29, 2016 7:59 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Nicole Casebolt ncasebolt23@gmail.com 1 Page 136 of 465 RR1 Box192D Poca, West Virginia 25159 Smith, Chris B From: Sent: To: Subject: Page 137 of 465 Lela Erb Friday, July 29, 2016 9:43 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Because my family owns land in WV, I work in WV and have been looking to move to WV, the Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Thank you, Sincerley, 1 Page 138 of 465 Lela Erb 228 Ingleside Ave., Marietta, OH 45740 Lela Erb erbl@suddenlink.net 228 Ingleside Ave., Marietta, Ohio 45750 2 Page 139 of 465 Smith, Chris B From: Sent: To: Subject: Kerren Hall Monday, August 01, 2016 10:57 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit. Permittees must follow the rules outlined in the Clean Water Act which require use attainability analysis in order to remove Category A use designation from our rivers and streams. Allowing removal of Category A use through the NPDES permit process will endanger public health and reduce protections for drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Thank you for the opportunity to comment. Kerren Hall kerrengh@yahoo.com 1 Page 140 of 465 167 hess rd Fayetteville, West Virginia 25840 Smith, Chris B From: Sent: To: Subject: Page 141 of 465 Paul Hancock Friday, August 05, 2016 11:16 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. In my opinion, the aim of any regulatory body for water standards should be water with zero 1 Page 142 of 465 pollution and that, of course, means stricter not slacker standards. Water is precious and should be treated as such. Thank you for the opportunity to comment. Paul Hancock paul@bouncinghedgehog.com 44 Little Queen Road Clendenin, West Virginia 25045 2 Smith, Chris B From: Sent: To: Subject: Page 143 of 465 Steven Runfola Friday, August 05, 2016 11:27 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 144 of 465 Thank you for the opportunity to comment. Steven Runfola stevenrunfola@gmail.com 45 Park Ridge Dr Morgantown, West Virginia 26508-4032 2 Smith, Chris B From: Sent: To: Subject: Page 145 of 465 Nancy Ward Friday, August 05, 2016 11:15 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 146 of 465 Thank you for the opportunity to comment. Nancy Ward naward57@gmail.com 703 Laurel road Charleston , West Virginia 25314 2 Page 147 of 465 Smith, Chris B From: Sent: To: Subject: Tom Nagle Friday, August 05, 2016 11:05 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, The reason we moved to Great Cacapon WV was BECAUSE of the beautiful Cacapon River and its high quality water. Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. 1 Page 148 of 465 Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. Tom Nagle Tom Nagle tom@tnagle.com 362 Fishers Bridge Lane Great Cacapon, West Virginia 25422 2 Smith, Chris B From: Sent: To: Subject: Page 149 of 465 Carroll Bassett Friday, August 05, 2016 11:20 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 150 of 465 Thank you for the opportunity to comment. Carroll Bassett bmsrescue@frontiernet.net HC 68 Box 64B Friars Hill, West Virginia 24938 2 Smith, Chris B From: Sent: To: Subject: Page 151 of 465 Janet Zerbe Friday, August 05, 2016 11:15 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 152 of 465 Thank you for the opportunity to comment. Janet Zerbe janetjz.1234@gmail.com 106 Shafer Road Dunbar, West Virginia 25064 2 Smith, Chris B From: Sent: To: Subject: Page 153 of 465 Luke Rostocki, MD Friday, August 05, 2016 11:18 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, I cannot think of a more important issue than protecting the waters in West Virginia. Please ,help luke a. rostocki, md Luke Rostocki, MD rostocki@aol.com 435 Dominick Circle Summersville, WV, West Virginia 26651 1 Smith, Chris B From: Sent: To: Subject: Page 154 of 465 Aaron Jewell Friday, August 05, 2016 11:13 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 155 of 465 Thank you for the opportunity to comment. Sincerely, Aaron Jewell Aaron Jewell ajewell82@gmail.com 30 Pappy Court Bunker Hill, West Virginia 25413 2 Smith, Chris B From: Sent: To: Subject: Page 156 of 465 Jean McAulay Friday, August 05, 2016 11:54 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 157 of 465 Thank you for the opportunity to comment. Jean McAulay chesbayretr@juno.com 10315 Geranium Ave Adelphi, Maryland 20783-1231 2 Smith, Chris B From: Sent: To: Subject: Page 158 of 465 Ross Andrew Friday, August 05, 2016 12:13 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 159 of 465 Thank you for the opportunity to comment. Ross Andrew randrew4@mix.wvu.edu 971 Valley View Ave Morgantown, West Virginia 26505 2 Smith, Chris B From: Sent: To: Subject: Page 160 of 465 Linda Christopher Friday, August 05, 2016 11:53 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 161 of 465 Thank you for the opportunity to comment. Linda Christopher lchristopher615@gmail.com P.O. Box 225 Snowshoe, West Virginia 26209 2 Smith, Chris B From: Sent: To: Subject: Page 162 of 465 Marilyn Mcgeorge Friday, August 05, 2016 12:11 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 163 of 465 Thank you for the opportunity to comment. Marilyn Mcgeorge mandw@suddenlink.net 1529 Virginia st east Charleston wv, West Virginia 25311 2 Smith, Chris B From: Sent: To: Subject: Page 164 of 465 Judy E. Hamilton Friday, August 05, 2016 11:51 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 165 of 465 Thank you for the opportunity to comment. Judy E. Hamilton annasmomjudy@yahoo.com 907 Mathews Ave Charleston, West Virginia 25302 2 Smith, Chris B From: Sent: To: Subject: Page 166 of 465 Ben Badger Friday, August 05, 2016 12:04 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 167 of 465 Thank you for the opportunity to comment. Ben Badger badger_benjamin@yahoo.com 216 Eastland Ave Morgantown, West Virginia 26505 2 Smith, Chris B From: Sent: To: Subject: Page 168 of 465 Eric Engle Friday, August 05, 2016 11:47 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 169 of 465 Thank you for the opportunity to comment. P.S. I live next to the Ohio River. The Ohio is considered one of if not the most polluted rivers in the country for the last 7 years running. West Virginians deserve cleaner, safer water than what we've become accustomed to. Eric Engle ericengle85@yahoo.com 324 Point Drive Parkersburg, West Virginia 26101 2 Smith, Chris B From: Sent: To: Subject: Page 170 of 465 Sandra Osbourn Friday, August 05, 2016 12:04 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 171 of 465 Thank you for the opportunity to comment. Sandra Osbourn ssosbourn301@gmail.com 134 Hensel Drive Shepherdstown, West Virginia 25443 2 Smith, Chris B From: Sent: To: Subject: Page 172 of 465 Rachael Pappano Friday, August 05, 2016 11:39 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 173 of 465 Thank you for the opportunity to comment. Rachael Pappano shamrock.magic@yahoo.com 330 River Rd. Mattawamkeag, Maine 04459 2 Smith, Chris B From: Sent: To: Subject: Page 174 of 465 Michael Klausing Friday, August 05, 2016 12:02 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 175 of 465 Thank you for the opportunity to comment. Michael Klausing mike_klausing@hotmail.com 624 Cross Lanes Dr Apt 11 Nitro, West Virginia 25143 2 Smith, Chris B From: Sent: To: Subject: Page 176 of 465 Art Glick Friday, August 05, 2016 11:37 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 177 of 465 Thank you for the opportunity to comment. Art Glick omb00900@mail.wvnet.edu HC 67 Box 539BB Renick, West Virginia 24966 2 Smith, Chris B From: Sent: To: Subject: Page 178 of 465 David Schles Friday, August 05, 2016 12:00 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 179 of 465 Thank you for the opportunity to comment. David Schles schles_law@wirefire.com 815 Quarrier Street, #306 Charleston, WV, West Virginia 25301 2 Smith, Chris B From: Sent: To: Subject: Page 180 of 465 Paul Burke Friday, August 05, 2016 1:22 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 181 of 465 Thank you for the opportunity to comment. Paul Burke paul@numbersinstitute.com PO Box 1320 Shepherdstown, West Virginia 25443 2 Smith, Chris B From: Sent: To: Subject: Page 182 of 465 Chris Preperato Friday, August 05, 2016 1:04 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 183 of 465 Thank you for the opportunity to comment. Chris Preperato chrispreperato@gmail.com 4101 Medford Drive Apt 3 Annandale, Virginia 22003 2 Smith, Chris B From: Sent: To: Subject: Page 184 of 465 Mark Leonard Friday, August 05, 2016 1:14 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 185 of 465 Thank you for the opportunity to comment. Mark Leonard mleonard8181@gamil.com 19499 Coshocton Rd. Mount Vernon, Ohio 43050 2 Smith, Chris B From: Sent: To: Subject: Page 186 of 465 James Dixon Friday, August 05, 2016 12:54 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 187 of 465 Thank you for the opportunity to comment. James Dixon james@harehill.com 206 W. Washington Ave. Terra Alta, West Virginia 26764 2 Smith, Chris B From: Sent: To: Subject: Page 188 of 465 Jenni Kovich Friday, August 05, 2016 1:09 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 189 of 465 Thank you for the opportunity to comment. Jenni Kovich jjkov1ch-charity@live.com 50 Dud Bennett Rd Leon, West Virginia 25123 2 Page 190 of 465 Comments On The Proposed Changes To The Amendment to Water Quality Standards Rule Prepared by Carpenter Environmental Associates, Inc. On behalf of the Affiliated Construction Trade Foundation August 2016 The West Virginia Department of Environmental Protection (WVDEP) Water Resources Division of Water and Waste Management as part of the triennial review has proposed changes related to regarding the critical design flow for compliance with human health water quality criteria. Specifically, WVDEP proposes replacing the use of the lowest 7-day average flow occurring on average once every 10 years (7Q10) with harmonic mean flow as the critical design flow for human health criteria effluent limits for carcinogens. We disagree with the WVDEP proposed change to allow Harmonic Mean Flow to be the critical design flow for determining the amount of a carcinogen an industry can legally discharge to the State’s waters. Critical Design Flow For Human Health Carcinogens We believe that adoption of the harmonic mean flow as the critical design flow for carcinogens is inappropriate for at least two reasons. First, the State has not adequately investigated the impact on all the streams of West Virginia of abandoning the use of a low design flow, such as the 7Q10, in favor of the harmonic mean flow. The effect of the rule change on our rivers has not been determined. The harmonic mean flow is always greater than the 7Q10 for a particular stream, therefore, the adoption of the harmonic mean flow as the critical design flow necessarily results in an increase in the amount of cancer causing chemicals allowed in all rivers and streams. The State must determine the magnitude of the increase in each river and stream in order to make a fully informed decision. Page 191 of 465 Second, the rationale for embracing harmonic mean flow as the critical design flow, as discussed in previous revision recommendations, is based upon the assumption that the linear lifetime exposure model for carcinogens is correct for all cancer causing substances (see Rationale Document, Water Resources Board of West Virginia, August 19, 1991). While the use of the linear lifetime exposure model for cancer may in many cases be conservative, we believe that applying such an assumption across-the-board for all cancer causing substances fails to account for valid alternative models for cancer. Establishing the harmonic mean flow as design flow rather than the 7Q10 would allow polluters to discharge up to 8 times (and perhaps more as would be determined in needed investigations) more cancer causing substances to West Virginia’s rivers and streams and would increase cancer risk. The increased cancer risk which would result by establishing harmonic mean flow as the design flow can and must be determined before allowing such a change. Therefore, we believe that the use of harmonic mean flow as the critical stream flow for carcinogens should not be allowed until it is fully investigated and the legislature determines that the increased cancer risk to the citizens of West Virginia is acceptable. Critical Design Flow for Non-Carcinogenic Human Health Criteria WVDEP has proposed that the critical design flow for human health criteria effluent limits for noncarcinogens be the minimum mean thirty consecutive day drought flow with a five year return frequency (30Q5). The recommended critical design flow would result in a less stringent design flow for non-carcinogenic human health criteria (30Q10 rather than 7Q10). Prior to changing the design flow for non-carcinogenic human health criteria from 7Q10 to 30Q10, an analysis must be conducted to evaluate the increased health risk to citizens of West Virginia of allowing increased levels of non-carcinogenic toxic pollutants to be discharged to the waters of West Virginia and the legislature must determine that the increased health risk is acceptable. This evaluation must take into Page 192 of 465 account that the neighboring Commonwealths of Kentucky and Pennsylvania both utilize the 7Q10 flow to determine discharge limitations for these pollutants. Smith, Chris B From: Sent: To: Subject: Page 193 of 465 MaryLois Gannon-Miller Friday, August 05, 2016 2:41 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 194 of 465 Thank you for the opportunity to comment. MaryLois Gannon-Miller marialouisa2001@yahoo.com 502 S George St Charles Town, West Virginia 25414 2 Smith, Chris B From: Sent: To: Subject: Page 195 of 465 jerry carson Friday, August 05, 2016 1:46 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 196 of 465 Thank you for the opportunity to comment. jerry carson jcarson1@suddenlink.net 5215 beechcrest dr cross lanes, West Virginia 25313 2 Smith, Chris B From: Sent: To: Subject: Page 197 of 465 William Hicks Friday, August 05, 2016 3:08 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, As a West Virginian and ecologist, I love this state in large part because of its forests and streams. I agree with the WV Rivers Coalition as described below: Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. 1 Page 198 of 465 Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. William Hicks whicks@bethanywv.edu 101 Roosevelt Ave Bethany, West Virginia 26032 2 Page 199 of 465 August 7, 2016 Comment on WV DEP Proposed Modi?cations to 47 CSR 2 WQS Rules: My name is Philip C. Price. I have a in Analytical Chemistry, with over 40 years' experience in industrial chemistry, trace analyses, epillfrelease incident investigations, and Superfund Site remediation. I have comments on two areas of the proposed changes: Drinking Water Use Designation DEP proposes to remove these designations of potential future source water use. One prediction we can all agree with is that WV will see more change in the future: new industries, shifting populations, economic challenges, and new environmental events (algae blooms, spill events, ?oods). Last summer's sudden algae bloom events clearly demonstrated the use?ilness of an alternate clean emergency water source for Huntington. Degrading our currently-available alternate water supplies increases ?iture risks to Public Health. This change seems driven mainly by manufacturers. Are there any data to demonstrate Speci?c WV economic bene?ts ?if we could only degrade the water quality of this speci?c stream?? Implement EPA-recommended Harmonic mean flow DEP proposes increasing the amount of permissible carcinogens (and other pollutants) in WV waters by changing the ?owidilution calculation factors. Some of the increases would be more than 10-fold, based on stream ?ow data. However, there is a lack of data on carcinogen and polutant identi?es, current concentrations, and proposed future concentrations. Without this data, the rule would be changed, but without any information as to its impact on Public Health or speci?c aquatic toxicity increase. W?w Philip C. Price 1391 Nottingham Rd. Charleston, WV 25314 PriceWV@gmail.c0m Smith, Chris B From: Sent: To: Subject: Page 200 of 465 Steven Presley Monday, August 08, 2016 8:29 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 201 of 465 Thank you for the opportunity to comment. Steven Presley Presley.Steven@mail.com 1838 Lovely Lane Letart, wv, West Virginia 25253 2 Smith, Chris B From: Sent: To: Subject: Page 202 of 465 Larry & Evelyn Dadisman Sunday, August 07, 2016 6:33 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 203 of 465 Thank you for the opportunity to comment. Larry & Evelyn Dadisman ldadisman@yahoo.com 912 Greendale Dr Charleston, West Virginia 25302-3224 2 Smith, Chris B From: Sent: To: Subject: Page 204 of 465 Christopher Benison Sunday, August 07, 2016 12:44 PM DEP Comments Laura Cooper, Water Quality Standards                         33 Maple Avenue                            Morgantown, West Virginia 26501                                                             August 7, 2016        Laura Cooper  Water Quality Standards  DWWM  WV Department of Environmental Protection  601 57th St. S.E.  Charleston, WV 25304    As a proud West Virginia resident, I am interested in protecting and even strengthening safe water resource standards.  The WVDEP is considering relaxing current regulations governing the protection and use of West Virginia’s water  resources. Such a decision is the wrong course for our state. Current regulations should be maintained and, in some  cases, even strengthened. At a minimum, I suggest the WVDEP take the following actions to protect our water  resources, now and in the  future:    1.  The WV‐DEP should adopt a 300 uS/com standard for electrical  conductivity in West Virginia Water Quality Standards. Water with higher conductivity than 300 uS/com is acutely toxic  to many species of aquatic life and therefore undermines biodiversity in a given water source. Biodiversity is a key  indicator for the overall health of a water system. Since conductivity is easily measured, numerous scientific studies and  EPA have concluded that electrical conductivity greater than 300 uS/com is harmful to aquatic life.    2.  The WV‐DEP should more aggressively protect Category A Drinking  Water Streams that can serve as a source of public drinking water. It is my understanding that WV‐DEP proposes  allowing pollution discharge permits to remove the Category A designation from a number of rivers and streams in the  state. WV‐DEP should reverse itself on this position and, at a minimum, delete sections 6.3 through 6.9 of the applicable  proposed rule. The language in the referenced sections would explicitly enable active pollution of the streams, which no  West Virginian should have to tolerate.    3.  The WV‐DEP should reject proposed changes to the “Critical Design  Flow.” The current proposal would allow higher rates of carcinogenic substances in current streamflows. Higher  carcinogen flow rates is particularly inappropriate during drought or other low flow periods but ideally should not be  allowed at all.    4.  The WV‐DEP should work toward a higher level of E. coli monitoring  in West Virginia water resources. Such E. coli monitoring is especially important for water resources used for  recreational purposes.    1 5.  The WV‐DEP should adopt the proposed EPA standards for five organic  Page 205 of 465 compounds (acrolein, carbaryl, diazinon, nonylphenol, and tributylin) in terms of their impacts on the quality of aquatic  life systems in West Virginia’s water resources.    These proposed steps represent a meaningful commitment to protect the quality of our state’s water resources and the  overall beauty of West Virginia. Thank you for the opportunity to express my opinion on this important issue.    Yours in good faith,        Christopher J. Benison  2 Smith, Chris B From: Sent: To: Subject: Page 206 of 465 Julie Archer Sunday, August 07, 2016 9:18 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 207 of 465 Thank you for the opportunity to comment. Julie Archer julie@wvcag.org PO Box 207 Sumerco, West Virginia 25567 2 Smith, Chris B From: Sent: To: Subject: Page 208 of 465 Steve Malafy Monday, August 08, 2016 7:52 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 209 of 465 Thank you for the opportunity to comment. Steve Malafy smalafy@gmail.com 280 Centerville Harp Rd French Creek, West Virginia 26218 2 Smith, Chris B From: Sent: To: Subject: Page 210 of 465 Gale Simplicio Sunday, August 07, 2016 6:30 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 211 of 465 Thank you for the opportunity to comment. Gale Simplicio galesviento@comcast.net 1275 Tartan Lane Morgantown, West Virginia 26505 2 Smith, Chris B From: Sent: To: Subject: Page 212 of 465 Grace Lynch Sunday, August 07, 2016 11:19 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 213 of 465 Thank you for the opportunity to comment. Grace Lynch gglynch@gmail.com PO Box 114 Rock Cave, 26234 2 Page 214 of 465 Smith, Chris B From: Sent: To: Subject: April Pierson-Keating Sunday, August 07, 2016 8:23 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, I am a citizen of West Virginia. I was born here. My mother, Iris Bell, wrote our state and centennial song, "This is My West Virginia." Iris loved our state and I have become an advocate for her environment and citizens. We are proud of our state and our heritage, and we don't want to see West Virginia's water quality and citizen health be destroyed in favor of corporations and industry. West Virginia is a national treasure. We have been abusing the environment and people for over a century. The new standards would undo national protective measures and make it harder to hunt, fish, and live in our state. It will also foul the water for those downstream. West Virginia is a water-producing state. Our water goes to 13 states and 46 rivers. We have a duty to keep it clean, not only for future generations of West Virginians, but for all those living downstream, and those who depend on the streams for their food, water, and livelihood. There could be no other reason for loosening the standards set in place by the Clean Water Act than to favor industry. We know that we can do better with a diversified economy, not a mono-economy. Coal, oil, and gas are killing the planet and poisoning the water, causing earthquakes, and putting radionuclides into our water. Your agency is one of those that is charged with protecting the streams and all those who depend on them, which is about 1/3 of the country, not to mention all the creatures in the food chain of this diverse state. Our biodiversity is second only to the Amazon Rain Forest, which we are also destroying at an alarming rate. Please consider the following as you make your decision: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The 1 Page 215 of 465 provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. April Pierson-Keating apkeating@hotmail.com 115 shawnee dr Buckhannon, Colorado wv 26201 2 Smith, Chris B From: Sent: To: Subject: Page 216 of 465 Doyle Coakley Sunday, August 07, 2016 10:55 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 217 of 465 Thank you for the opportunity to comment. Doyle Coakley dcoakley@frontiernet.net P O Box 245 Cowen, West Virginia 26206 2 Page 218 of 465 Smith, Chris B From: Sent: To: Subject: Kent Higgins Sunday, August 07, 2016 4:14 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, I appreciate the opportunity to comment on the Water Standards. Some of what follows is the wording of the West Virginia Rivers Coalition, whose positions I support in general. I have left out some of their points in order to say to you that I view clean, safe water as critical to the future of West Virginia - it is in fact the last natural resource which we have in abundance and which is desired by others - we would be fools to adopt standards which allowed further degradation of water quality. We should be improving quality. I am from Fayetteville, which now relies on tourism as its industry. The coal business, which supported my family and many others for so long, is declining and not coming back. Tourism is our current growth industry, and we desperately need it. In my youth (I am nearly 72) a significant obstacle to tourism was that one could not purchase liquor by the drink. The point was made over and over than tourists would look at the beauty of our state during the day, but they wanted a drink with dinner. Churches preached against it as sinful, but eventually rational minds prevailed and tourism increased. Do you think that tourists want to encounter polluted water as part of their West Virginia experience? I realize that some see the proposed changes as incremental and not significant, but I think the issue is so important that any slippage is bad. For too long, the people of this state have traded their right to a clean and safe working environment for current jobs. Now that the jobs are gone, we're left with the environmental mess. Let's not repeat that part of our history. Here are some of WVRC's points: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The 1 Page 219 of 465 provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. Kent Higgins Kent Higgins revkenthiggins@gmail.com 1520 Dogwood Rd Charleston, West Virginia 25314 2 Smith, Chris B From: Sent: To: Subject: Page 220 of 465 codya.jones10@gmail.com Sunday, August 07, 2016 11:22 AM DEP Comments WV-DEP Water Standards Hearing Aug. 9 Laura Cooper, WV‐DEP,     As a member of the US Army currently stationed in Fort Benning, GA. I'm from Ona, WV where my wife still currently  lives, and we'd like to have a family in WV but we want our children to have a better WV than we inherited. We know  that the grass is greener on the other‐side especially in Maryland but West Virginia is home. I'd like to ask for five favors  to improve the quality of the water in my home state.                      Five Key “Asks”    1)         Include a 300 uS/cm standard for electrical conductivity in West Virginia Water Quality Standards.  Electrical  conductivity is abroad measure of the level of chemical ions such as sulfate, bicarbonate, calcium, chlorides, and many  other dissolved solids.  Sources include mining operations, gas well development, road salts, and other activities.  Water  high in conductivity is acutely toxic to many species of aquatic life.  Since conductivity is easily measured, numerous  scientific studies and EPA have concluded that electrical conductivity greater than 300 uS/cm is harmful to aquatic life.     2)         Protect “Category A Drinking Water”.  Streams that can serve as sources of public drinking water are designated  “Category A”.  Current standards apply this designation to almost all waters in West Virginia, thereby protecting those  streams for current and future water supplies.  WV‐DEP proposes to allow pollution discharge permits to remove this  Category A designation from a stream.  Urge DEP to delete sections 6.3 through 6.9 of the proposed rule.  This proposed  language is entirely focused on allowing more pollution.  Tell WV‐DEP that Water Quality Standards should be about  protecting drinking water and other water uses!    3)         Reject proposed changes to the “Critical Design Flow”.  The Critical design Flow is used to estimate the water’s  flow rate in receiving streams.  WV‐DEP proposes to change this calculation to allow higher rates of carcinogens in  water.  While EPA has supported this in some cases, it is not appropriate during drought or low flow periods because  that will allow higher concentrations of carcinogens.  Demand that WV‐DEP establish procedures to reduce the amount  of carcinogens during low flow periods.    4)         Require increased monitoring of E. coli and fecal coliform bacterial contamination.  Water with high levels of fecal  coliform bacteria is unsafe for recreation.  Ask WV‐DEP to increase the required sampling frequency to assure safety for  swimming and boating.    5)         Adopt as proposed EPA’s recommended standards for aquatic life criteria for five organic chemicals; acrolein,  carbaryl, diazinon, nonylphenol, and tributyltin.  These compounds are toxic and West Virginia needs these water quality  standards.      Thank you for helping to protect West Virginia's water.    Sincerely,  2LT Cody A. Jones   1 Smith, Chris B From: Sent: To: Subject: Page 221 of 465 Mary A Borchers Sunday, August 07, 2016 12:44 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 222 of 465 Thank you for the opportunity to comment. Mary A Borchers abigail@raven-villages.net 1801 Middle Ridge Rd Romney, West Virginia 26757 2 Smith, Chris B From: Sent: To: Subject: Page 223 of 465 Lori Magana Sunday, August 07, 2016 7:32 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Please protect our water. Please keep Category A standards as we have utilized over these last years. Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 224 of 465 Thank you for the opportunity to comment. Lori Magana lorimagana@gmail.com 304 Gail Drive Charleston, West Virginia 25314 2 Smith, Chris B From: Sent: To: Subject: Page 225 of 465 Helen Gibbins Sunday, August 07, 2016 3:24 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, The League of Women Voters of WV wishes to make comments on WV's Water Quality Standards. In general we urge the protection of our waters for now and the future. We oppose weakening the standards as well as increasing pollution into WV's waters. We need to protect our waters for human and fauna health. If more pollution is allowed, the costs of cleaning up the pollution will also go up. 1. We oppose allowing Category A use for the waters of our state to be changed through NPDES permits. Variances from Category A use need full reviews and studies to ensure downstream waters uses are protected. 2. Changing the way flow of the waters are determined needs a full study in conjunction with the USGS. The method used should take into account the lowest flow of the waters. 3. The procedure for determining bacterial count in our waters should use both Fecal Coliform and E. Coli until it is determined which is the more accurate system. 4. Adopt EPA's recommended standards for aquatic life criteria for organic chemicals. Thank you for allowing us to comment on the Triennial Review. League of Women Voters of WV President, Nancy Novak, and board member, Helen Gibbins Helen Gibbins gibbins@frontier.com 6128 Gideon Huntington, WV, West Virginia 25705 1 Smith, Chris B From: Sent: To: Subject: Page 226 of 465 Colleen Anderson Sunday, August 07, 2016 11:01 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 227 of 465 Thank you for the opportunity to comment. Colleen Anderson motherwit@suddenlink.net 6 Arlington Court Charleston , West Virginia 25301 2 Page 228 of 465 Smith, Chris B From: Sent: To: Subject: jim hatfield Saturday, August 06, 2016 10:47 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Although West Virginia will continue to mine less coal, it can share its other natural resources more, including abundant and clean water. Do not allow our overall water quality to be degraded by changing the Category A criteria through an NPDES or any other permit. If a business or industry cannot afford to discharge safe, clean water, they are not paying all their expenses and, instead, shifting the cost to the public domain. Do not shift to a new method of measuring stream flow without understanding, through a statewide scientific study, how the proposed method compares to the current one. Let science dictate which is best or if they both have a place in producing the most accurate numbers. Also allow science to determine the differences between measuring E. Coli and Fecal Coliform as a gauge of public water safety. Adequate sampling frequency must also be taken into account. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. jim hatfield hatfield.jch@gmail.com 1077 foley drive saint albans, West Virginia 25177 1 Smith, Chris B From: Sent: To: Subject: Page 229 of 465 Scott Price Monday, August 08, 2016 1:23 PM DEP Comments I'm the 6th signer: "Protect West Virginia Water" Dear 47CSR2 Water standards rule comments, I just signed a petition addressed to you titled Protect West Virginia Water. So far, 18 people have signed the petition. You can reach me directly by replying to this email. Or, post a response for MoveOn.org to pass along to all petition signers by clicking here: http://petitions.moveon.org/target_talkback.html?tt=tt-112579-custom73331-20260808-MPKRic The petition states: "Reject proposed weakening of WV water quality standard 47CSR2. WVDEP should: reject the “harmonic flow” estimate that would allow higher levels of carcinogenic discharges, and instead work with USGS to develop an estimate that accounts for low flow conditions; remove the change that allows a pollution permit to remove Category A drinking water designation from streams; develop a procedure that measures both Fecal Coliform and E. Coli as bacterial indicators for water recreation safety; adopt EPA’s recommended standards for aquatic life criteria; and adopt a 300 uS/cm conductivity standard to protect aquatic life from mine runoff and other threats." My additional comments are: You can't keep people from their God giving Rights To download a PDF file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838571&target_type=custom&target_id=73331 To download a CSV file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838571&target_type=custom&target_id=73331&csv=1 Scott Price Cleveland, OH This email was sent through MoveOn's public petition website, a free service that allows anyone to set up their own online petition and share it with friends. MoveOn does not endorse the contents of petitions posted on our public petition website. If you have any questions, please email petitions@moveon.org. If you don't want to receive further emails updating you on how many people have signed this petition, click here: http://petitions.moveon.org/delivery_unsub.html?e=tVUo0ChI09uo.VobkFLowERFUC5Db21tZW50c0B3di5nb 3Y-&petition_id=112579. 1 Smith, Chris B From: Sent: To: Subject: Page 230 of 465 Debbie Jarrell Monday, August 08, 2016 1:23 PM DEP Comments I'm the 2nd signer: "Protect West Virginia Water" Dear 47CSR2 Water standards rule comments, I just signed a petition addressed to you titled Protect West Virginia Water. So far, 18 people have signed the petition. You can reach me directly by replying to this email. Or, post a response for MoveOn.org to pass along to all petition signers by clicking here: http://petitions.moveon.org/target_talkback.html?tt=tt-112579-custom73331-20260808-MPKRic The petition states: "Reject proposed weakening of WV water quality standard 47CSR2. WVDEP should: reject the “harmonic flow” estimate that would allow higher levels of carcinogenic discharges, and instead work with USGS to develop an estimate that accounts for low flow conditions; remove the change that allows a pollution permit to remove Category A drinking water designation from streams; develop a procedure that measures both Fecal Coliform and E. Coli as bacterial indicators for water recreation safety; adopt EPA’s recommended standards for aquatic life criteria; and adopt a 300 uS/cm conductivity standard to protect aquatic life from mine runoff and other threats." My additional comments are: Please, our kids and grandkids do matter! To download a PDF file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838568&target_type=custom&target_id=73331 To download a CSV file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838568&target_type=custom&target_id=73331&csv=1 Debbie Jarrell rock creek, WV This email was sent through MoveOn's public petition website, a free service that allows anyone to set up their own online petition and share it with friends. MoveOn does not endorse the contents of petitions posted on our public petition website. If you have any questions, please email petitions@moveon.org. If you don't want to receive further emails updating you on how many people have signed this petition, click here: http://petitions.moveon.org/delivery_unsub.html?e=tVUo0ChI09uo.VobkFLowERFUC5Db21tZW50c0B3di5nb 3Y-&petition_id=112579. 1 Smith, Chris B From: Sent: To: Subject: Page 231 of 465 Janet Perry Monday, August 08, 2016 1:23 PM DEP Comments I'm the 7th signer: "Protect West Virginia Water" Dear 47CSR2 Water standards rule comments, I just signed a petition addressed to you titled Protect West Virginia Water. So far, 18 people have signed the petition. You can reach me directly by replying to this email. Or, post a response for MoveOn.org to pass along to all petition signers by clicking here: http://petitions.moveon.org/target_talkback.html?tt=tt-112579-custom73331-20260808-MPKRic The petition states: "Reject proposed weakening of WV water quality standard 47CSR2. WVDEP should: reject the “harmonic flow” estimate that would allow higher levels of carcinogenic discharges, and instead work with USGS to develop an estimate that accounts for low flow conditions; remove the change that allows a pollution permit to remove Category A drinking water designation from streams; develop a procedure that measures both Fecal Coliform and E. Coli as bacterial indicators for water recreation safety; adopt EPA’s recommended standards for aquatic life criteria; and adopt a 300 uS/cm conductivity standard to protect aquatic life from mine runoff and other threats." My additional comments are: The destruction of miles upon miles of streams in West Virginia due to the practice of Mountaintop Removal (or 'bombing' as it should be called... ) by the coal industry is, in and of itself a travesty of humanity and justice. The destruction of this vital part of local ecosystems, as well as the drinking water of hundreds of thousands of people is something that cannot be overlooked. The state and federal government must step up and hold the coal industry responsible for the clean-up of its mess. To download a PDF file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838569&target_type=custom&target_id=73331 To download a CSV file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838569&target_type=custom&target_id=73331&csv=1 Janet Perry San Clemente, CA This email was sent through MoveOn's public petition website, a free service that allows anyone to set up their own online petition and share it with friends. MoveOn does not endorse the contents of petitions posted on our public petition website. If you have any questions, please email petitions@moveon.org. If you don't want to 1 receive further emails updating you on how many people signed this petition, click here: Page 232have of 465 http://petitions.moveon.org/delivery_unsub.html?e=tVUo0ChI09uo.VobkFLowERFUC5Db21tZW50c0B3di5nb 3Y-&petition_id=112579. 2 Page 233 of 465 Smith, Chris B From: Sent: To: Subject: Mark Graham Monday, August 08, 2016 1:23 PM DEP Comments I'm the 13th signer: "Protect West Virginia Water" Dear 47CSR2 Water standards rule comments, I just signed a petition addressed to you titled Protect West Virginia Water. So far, 18 people have signed the petition. You can reach me directly by replying to this email. Or, post a response for MoveOn.org to pass along to all petition signers by clicking here: http://petitions.moveon.org/target_talkback.html?tt=tt-112579-custom73331-20260808-MPKRic The petition states: "Reject proposed weakening of WV water quality standard 47CSR2. WVDEP should: reject the “harmonic flow” estimate that would allow higher levels of carcinogenic discharges, and instead work with USGS to develop an estimate that accounts for low flow conditions; remove the change that allows a pollution permit to remove Category A drinking water designation from streams; develop a procedure that measures both Fecal Coliform and E. Coli as bacterial indicators for water recreation safety; adopt EPA’s recommended standards for aquatic life criteria; and adopt a 300 uS/cm conductivity standard to protect aquatic life from mine runoff and other threats." My additional comments are: Clean Water is for everyone To download a PDF file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838570&target_type=custom&target_id=73331 To download a CSV file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838570&target_type=custom&target_id=73331&csv=1 Mark Graham Hyattsville, MD This email was sent through MoveOn's public petition website, a free service that allows anyone to set up their own online petition and share it with friends. MoveOn does not endorse the contents of petitions posted on our public petition website. If you have any questions, please email petitions@moveon.org. If you don't want to receive further emails updating you on how many people have signed this petition, click here: http://petitions.moveon.org/delivery_unsub.html?e=tVUo0ChI09uo.VobkFLowERFUC5Db21tZW50c0B3di5nb 3Y-&petition_id=112579. 1 Page 234 of 465 August 8, 2016 Laura Cooper Water Quality Standards, DWWM WV Department of Environmental Protection 601 57th St. S.E. Charleston, WV 25304 Re: Proposed Triennial Review of Legislative Rule 47CSR2, “Requirements Governing Water Quality Standards” Dear Ms. Cooper, Thank you for this opportunity to provide comments on the items to be considered during the West Virginia Department of Environmental Protection’s (DEP) 2016 Triennial Review of aquatic life water quality standards, on behalf of our client, the Copper Development Association (CDA). CDA played a significant role in sponsoring scientific research used in the development of the freshwater Biotic Ligand Model (BLM) for copper, which was adopted by the United States Environmental Protection Agency (USEPA) as the basis for its latest nationally recommended freshwater aquatic life ambient water quality criteria for copper (USEPA 2007). The purpose of this letter is to support DEP’s proposed rule which includes language to allow the BLM to be used to derive site-specific criteria for copper. We are encouraged to see the adoption of criteria derivation methods that more accurately predict copper bioavailability compared to the existing hardnessbased standard. While the model is useful for derivation of site-specific water quality criteria, we suggest its best application is on a state-wide basis for any discharger with sufficient water quality data to run the BLM. We suggest that the DEP explore full replacement of the hardness-based standards with the BLM, or include the BLM as a site-wide alternative. Several states are already working towards full replacement of the hardness-based criteria for copper with the BLM as the basis (i.e., DE, ID, KS, and OR). This would enable individual permit writers and permittees to collaborate directly to use the BLM to derive permit limits, thereby minimizing or eliminating the need to go through a lengthy and expensive rulemaking process. BLM-based criteria provide a practical means of deriving demonstrably more accurate levels of aquatic life protection across a broad range of water quality conditions, and with sufficient flexibility to support most any regulatory application framework. We appreciate the opportunity to provide comments on the topic to consider for updating West Virginia’s water quality standards. Please let us know if you have any questions. We look forward to discussing this with you further. Page 235 of 465 Sincerely, GEI CONSULTANTS, INC. Robert W. Gensemer, Ph.D., GEI Senior Ecotoxicologist Carrie Claytor, CDA Director of Health, Environment and Sustainable Development RWG cc: Steven Canton, GEI John Gondek, GEI David DeForest, Windward Environmental Eric Van Genderen, International Zinc Association References U.S. Environmental Protection Agency (USEPA). 2007. Aquatic Life Ambient Freshwater Quality Criteria – Copper. EPA-822-R-07-001. U.S. Environmental Protection Agency, Washington, D.C. Smith, Chris B From: Sent: To: Subject: Page 236 of 465 Shane Assadzandi Monday, August 08, 2016 12:57 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 237 of 465 Thank you for the opportunity to comment. Shane Assadzandi shane.assadzandi.wv@gmail.com 106 Ashley Oaks Morgantown, West Virginia 26505 2 Smith, Chris B From: Sent: To: Subject: Page 238 of 465 Ferold Torchenot Monday, August 08, 2016 12:51 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 239 of 465 Thank you for the opportunity to comment. Ferold Torchenot feroldtorchenot@yahoo.com 7080Cradlerock way COLUMBIA, Maryland 21045 2 Page 240 of 465 Smith, Chris B From: Sent: To: Subject: JL Summers Monday, August 08, 2016 12:20 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, It is hard to believe anyone would think it proper to weaken water standards. Please stop kowtowing to industries asking this be done. The citizens of WV are being done a large disservice by the WVDEP. It is no wonder WV continues to loose population every year. Cater to the residence population that deserves clean pure water both to drink and for recreation. Thank you. JL Summers summersimac@frontier.com 13004 Winfield Rd Winfield, West Virginia 25213 1 Smith, Chris B From: Sent: To: Subject: Page 241 of 465 Norma Miller Monday, August 08, 2016 1:10 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 242 of 465 Thank you for the opportunity to comment. Norma Miller n0k9miller@aol.com 2010 Weberwood Dr. Charleston, West Virginia 25303 2 Smith, Chris B From: Sent: To: Subject: Page 243 of 465 Betsy Reeder Monday, August 08, 2016 12:57 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 244 of 465 Thank you for the opportunity to comment. Betsy Reeder ereeder44@msn.com HC 85 Box 305 Jumping Branch, West Virginia 25969 2 Smith, Chris B From: Sent: To: Subject: Page 245 of 465 Elise Keaton Monday, August 08, 2016 12:08 PM DEP Comments Protect our water!! Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Please reject the proposal to allow removal of Category A drinking water protection through the permitting process. I support protecting all waters as current or future drinking water sources and oppose any rollback of this long-standing policy. Please reject changes to the “critical design flow” that would allow more carcinogens into our water. WVDEP proposes to change flow rate calculation to a system that is not as protective during low water or drought conditions, allowing for higher, more dangerous concentrations of pollutants into our water. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. I recommend WVDEP work with the USGS to conduct a statewide study to determine the best estimates for flow. Please support increased statewide monitoring for bacteria in our waters. I support using E. Coli, instead of Fecal Coliform, as the new bacterial indicator as long as a procedure is in place to monitor both indicators during the transition process, and that frequency of sampling is adequate to measure a monthly average value. Please adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 246 of 465 Sincerely, Elise Keaton Elise Keaton elise.keaton@gmail.com PO Box 481 Hinton, WV, West Virginia 25951 2 Smith, Chris B From: Sent: To: Subject: Page 247 of 465 Linda Farwell Monday, August 08, 2016 1:01 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 248 of 465 Thank you for the opportunity to comment. Linda Farwell farwell4775@gmail.com 756 Gordon Drive Charleston, West Virginia 25303 2 Smith, Chris B From: Sent: To: Subject: Page 249 of 465 Joseph Sandy Monday, August 08, 2016 12:56 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 250 of 465 Thank you for the opportunity to comment. Joseph Sandy josephsandy040@aol.com 103 Pinewood Road Clarksburg, West Virginia 26330 2 Smith, Chris B From: Sent: To: Subject: Page 251 of 465 Angela Hughes Monday, August 08, 2016 12:30 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 252 of 465 Thank you for the opportunity to comment. Angela Hughes scampyhughes@aol.com 2101 Rays Branch Road Charleston, West Virginia 25314 2 Smith, Chris B From: Sent: To: Subject: Page 253 of 465 wes holliday Monday, August 08, 2016 12:02 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, We do not need to go back to the old ways, when the river actually caught on fire, when you could not eat the fish, or swim in the waters. West Virginia needs to go forward, we have never had progress when we sold out our Environment to 'out of state" interests, or manufacturers. Every time we compromise our environment for a few jobs, it ends up hurting all of us ! Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. 1 Page 254 of 465 Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. wes holliday wes@suddenlink.net 141 notyurbusiness charleston, West Virginia 25311 2 Page 255 of 465 Smith, Chris B From: Sent: To: Subject: Steve Cantley Monday, August 08, 2016 1:23 PM DEP Comments I'm the 12th signer: "Protect West Virginia Water" Dear 47CSR2 Water standards rule comments, I just signed a petition addressed to you titled Protect West Virginia Water. So far, 18 people have signed the petition. You can reach me directly by replying to this email. Or, post a response for MoveOn.org to pass along to all petition signers by clicking here: http://petitions.moveon.org/target_talkback.html?tt=tt-112579-custom73331-20260808-MPKRic The petition states: "Reject proposed weakening of WV water quality standard 47CSR2. WVDEP should: reject the “harmonic flow” estimate that would allow higher levels of carcinogenic discharges, and instead work with USGS to develop an estimate that accounts for low flow conditions; remove the change that allows a pollution permit to remove Category A drinking water designation from streams; develop a procedure that measures both Fecal Coliform and E. Coli as bacterial indicators for water recreation safety; adopt EPA’s recommended standards for aquatic life criteria; and adopt a 300 uS/cm conductivity standard to protect aquatic life from mine runoff and other threats." My additional comments are: save our streams PLEASE To download a PDF file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838572&target_type=custom&target_id=73331 To download a CSV file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838572&target_type=custom&target_id=73331&csv=1 Steve Cantley Naoma, WV This email was sent through MoveOn's public petition website, a free service that allows anyone to set up their own online petition and share it with friends. MoveOn does not endorse the contents of petitions posted on our public petition website. If you have any questions, please email petitions@moveon.org. If you don't want to receive further emails updating you on how many people have signed this petition, click here: http://petitions.moveon.org/delivery_unsub.html?e=tVUo0ChI09uo.VobkFLowERFUC5Db21tZW50c0B3di5nb 3Y-&petition_id=112579. 1 Page 256 of 465 Smith, Chris B From: Sent: To: Subject: Rodney Hytonen Monday, August 08, 2016 1:44 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Why ANY Fossil Fuel facilities are being, or have been, permitted in West Virginia, is completely beyond my understanding, and that of any thinking person. And the immediate proof of its harm, in the real world, continues to torture many thousands of West Virginians daily, myself and my family very much included. Our (nightly, now) asthma has gone through the roof, and I had until now, only had ONE attack in 68 years! Ghis began when the drilling and fracking pads north of our town, Pennsboro, grew from 11 pads to over 75 Pads recently, according to ARCGIS and the Earthworks online map! West Virginia is suffering from the irresponsible proliferation of this EXPORT-level gas drilling and fracking. We will not forget it, as we grow to recognize the source, the corrupt enablers, and the feculent reason -irresponsible greed- for all this permanent harm and immediate suffering. Our government agencies were created to PROTECT the people from its harm - not to ENABLE it! The still-emerging scientific proof is already overwhelming, that the use of fossil fuels has been a two century long, colossal mistake, made by mankind out of the pure, irresponsible greed of a few criminally harmful industries, and their lies that these deadly and death-dealing "jobs" are "the only ones available." We could easily have made other, far less harmful jobs- and energy sources- available. END the drilling, fracking, piping, shipping, and other EXPORTING of our very land from beneath us, do it overnight! Create those jobs NOW, to actually clean it up (not just the cosmetic minimum) and pay for them by exacting ALL the losses and costs, in Public Health, Infrastructure, and 1 Page 257 of 465 Private Property; which the Industries have EXTERNALIZED to a public that could ill afford them. How much LESS will we be able to afford it, when the inevitable BUST comes. Have we learned NOTHING? PLEASE do not allow this facility to be built or operated AT ALL, and mandate an immediate END to the MISTAKE of protecting and enabling this irresponsible, marauding, poisonous, devastating industry of nonconventional, horizontal drilling and "slickwater" hydraulic fracturing; NOW. Protect the people's health, our mountains wildlife, and streams, and the planet NOT CORPORATE PROFITS. BANKRUPT this criminal imdusry, SEIZE their assets, NATIONALIZE energy to keep our resources HERE, and CREATE those new Green Energy jobs TODAY. Rodney Hytonen rodneyhytonen@frontier.com 109 Pine Drive Pennsboro, West Virginia 26415 2 Smith, Chris B From: Sent: To: Subject: Page 258 of 465 Jacqueline Stalnaker Monday, August 08, 2016 1:27 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 259 of 465 Thank you for the opportunity to comment. Jacqueline Stalnaker jmstalnaker@outlook.com 19091 Barbour County Ave Philippi, West Virginia 26416 2 Smith, Chris B From: Sent: To: Subject: Page 260 of 465 Patricia Gundrum Monday, August 08, 2016 1:48 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 261 of 465 Thank you for the opportunity to comment. Patricia Gundrum gundrum2@gmail.com 252 STAUNTON AVE SOUTH CHARLESTON, West Virginia 25303 2 Smith, Chris B From: Sent: To: Subject: Page 262 of 465 Lucy Jenkins Monday, August 08, 2016 1:43 PM DEP Comments Water Quality Standards Laura Cooper, Hello Laura, I have been concerned for some time about the quality of our drinking water here in West Virginia. We constantly receive notifications that we are not to drink the water because of potential contamination. Water is a basic necessity, and whilst I realize we have cleaner water than most developing countries, it is of grave concern to me that I and several of my friends and acquaintances have developed cancerous tumors in the 16 years since I have lived in this area. We need to make water quality a priority. Please ensure our drinking and cooking water is safe. Please also work to develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. It has been suggested I ask you to adopt the proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Much of the chemistry of this is unclear to me, but I am currently buying water from the grocery store or otherwise filling containers from sources outside the town. Thank you so much for the opportunity to comment. Lucy Jenkins lumaze@hotmail.com 15 Valley Court Shepherdstown, West Virginia 25443 1 Smith, Chris B From: Sent: To: Subject: Page 263 of 465 George Little Monday, August 08, 2016 1:59 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 264 of 465 Thank you for the opportunity to comment. George Little george.wilbur.little@gmail.com 307 Hillside Pass Frankford, West Virginia 24938 2 Smith, Chris B From: Sent: To: Subject: Page 265 of 465 Michael McLeod Monday, August 08, 2016 2:42 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 266 of 465 Thank you for the opportunity to comment. Michael McLeod holdfastmclemi@gmail.com 4 Penrose Street White Hall, West Virginia 26554 2 Smith, Chris B From: Sent: To: Subject: Page 267 of 465 Dorris Headden Monday, August 08, 2016 3:20 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 268 of 465 Thank you for the opportunity to comment. Dorris Headden dorrie6s@comcast.net 399 All American Way MARTINSBURG, West Virginia 25405 2 Smith, Chris B From: Sent: To: Subject: Page 269 of 465 Michael Condon Monday, August 08, 2016 3:39 PM DEP Comments I'm the 40th signer: "Protect West Virginia Water" Dear 47CSR2 Water standards rule comments, I just signed a petition addressed to you titled Protect West Virginia Water. So far, 40 people have signed the petition. You can reach me directly by replying to this email. Or, post a response for MoveOn.org to pass along to all petition signers by clicking here: http://petitions.moveon.org/target_talkback.html?tt=tt-112579-custom73331-20260808-MPKRic The petition states: "Reject proposed weakening of WV water quality standard 47CSR2. WVDEP should: reject the “harmonic flow” estimate that would allow higher levels of carcinogenic discharges, and instead work with USGS to develop an estimate that accounts for low flow conditions; remove the change that allows a pollution permit to remove Category A drinking water designation from streams; develop a procedure that measures both Fecal Coliform and E. Coli as bacterial indicators for water recreation safety; adopt EPA’s recommended standards for aquatic life criteria; and adopt a 300 uS/cm conductivity standard to protect aquatic life from mine runoff and other threats." My additional comments are: Legislators seem to have little regard for our state's water ways. We need higher standards to protect our drinking water. Additionally the Birthplace of Rivers National Monument would illustrate a commitment to honoring the value of water to everyone. To download a PDF file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838611&target_type=custom&target_id=73331 To download a CSV file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838611&target_type=custom&target_id=73331&csv=1 Michael Condon Hillsboro, WV This email was sent through MoveOn's public petition website, a free service that allows anyone to set up their own online petition and share it with friends. MoveOn does not endorse the contents of petitions posted on our public petition website. If you have any questions, please email petitions@moveon.org. If you don't want to receive further emails updating you on how many people have signed this petition, click here: 1 http://petitions.moveon.org/delivery_unsub.html?e=tVUo0ChI09uo.VobkFLowERFUC5Db21tZW50c0B3di5nb Page 270 of 465 3Y-&petition_id=112579. 2 Smith, Chris B From: Sent: To: Subject: Page 271 of 465 Natalie Thompson Monday, August 08, 2016 2:25 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 272 of 465 Thank you for the opportunity to comment. Natalie Thompson Thompson4change@gmail.com 140 Westview Avenue Huntington, West Virginia 25701 2 Smith, Chris B From: Sent: To: Subject: Page 273 of 465 Elizabeth Scott Monday, August 08, 2016 2:36 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 274 of 465 Thank you for the opportunity to comment. Elizabeth Scott scottbetsy40@gmail.com 114 Shady Ln Winfield, West Virginia 25213 2 Smith, Chris B From: Sent: To: Subject: Page 275 of 465 Monique TONET Monday, August 08, 2016 3:25 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 276 of 465 Thank you for the opportunity to comment. Monique TONET tonet.monique@neuf.fr 14 boulevard Jean Baptiste Verany Nice, Provence-Alpes-Côte d'Azur 06300 2 Smith, Chris B From: Sent: To: Subject: Page 277 of 465 Thomas Bouldin Monday, August 08, 2016 3:19 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Increasingly the state's lawmakers seem to believe that lowering demands on industry we can somehow get people to invest in the state's economy. That is a foolish and ill-conceived strategy. If our state's environment is more seriously polluted because of reduced regulatory standards, there will be less meaningful investment, not more. Keep our water quality standards protective of public health and recreational safety. This is more productive long-term investment than some cow-towing to corporate demands to oppose Federal Standards for protection of environment. Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Such detailed testing may be more timeconsuming and more expensive, but the results are far more empowering than any inconveniences entailed by meeting high expectations. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Current misrepresentations of flow rates by various gas-industry interests show that we really must 1 Page 278 of 465 insist on such standard measures as are supplied by national organizations like USGS. More localized and less rigorous standards will ultimately work against the state and its people. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. I have been deeply concerned about the DEP's evaluation of water-related issues as impacted by the Mountain Valley Pipeline proposal, and will be sending further expressions of that concern as time permits. Sincerely Thomas T. Bouldin Pence Springs, WV Thomas Bouldin tybouldin@outlook.com PO Box 431 Talcott, WV, West Virginia 24910 2 Smith, Chris B From: Sent: To: Subject: Page 279 of 465 Beth Covington Monday, August 08, 2016 2:33 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 280 of 465 Thank you for the opportunity to comment. Beth Covington covington925@hotmail.com PO Box 57 Greenville, WV, West Virginia 24945 2 Smith, Chris B From: Sent: To: Subject: Page 281 of 465 Rick Abel Monday, August 08, 2016 3:32 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 282 of 465 Thank you for the opportunity to comment. Rick Abel rickabel@excite.com P. O. Box 431 Pursglove, West Virginia 26546 2 Smith, Chris B From: Sent: To: Cc: Subject: Page 283 of 465 Robin J Reash Monday, August 08, 2016 12:41 PM Cooper, Laura K Smith, Chris B; Jill N Lukehart; Alan R Wood AEP comments - proposed rules for 2017 triennial review Hello Laura.  American Electric Power (AEP) submits the following comments on proposed changes to the “Requirements  Governing Water Quality Standards, 47 CRS 2”.   AEP submitted comments in 2014 and 2015 regarding our suggested  changes to the water quality standards (WQS) pursuant to the 2017 triennial review.       Category A Use Designation:  we appreciate DEP allowing some flexibility to the regulated community  concerning mechanisms to demonstrate that the Category A use is not appropriate on a site‐specific basis.   We  believe that the proposed provisions do not go far enough, however.  They are administratively onerous and can  be challenged by 3rd‐parties and/or US EPA.  We request that DEP re‐consider the common‐sense approach to  Category A.  This use designation should only apply when an actual drinking water intake is located at a  reasonable distance from a permitted facility.   This would allow adequate protection for raw river water quality  and not incur significant wastewater treatment costs for a facility not located proximal to an intake.  This  scheme is also predictable ‐  a regulated entity and all stakeholders know, in advance, what criteria apply when  there is a new source or an expanded source of an existing discharge.   If, despite these recommendations, DEP  decides to finalize the proposed changes considering applicability of Category A criteria, we believe a  cost/benefit analysis should be conducted, i.e., what are the treatment (economic) costs relative to the  environmental benefits of all waterbody segments attaining the Category A use criteria?  The regulated  community can forecast the cost implications of attaining certain criteria in downstream water.  To be fair to  them, an understanding of the environmental or human  health benefits should be made available.     Default permitting flow: We support DEP’s proposed provision that the harmonic mean streamflow be used for  deriving wasteload allocations regarding carcinogenic pollutants (human health protection).         AEP supports the comments submitted by the West Virginia Manufacturers Association.      Feel free to contact me at 614‐716‐1237 if you have any comments on the above comments.    Rob Reash  American Electric Power – Environmental Services Department  Consulting Environmental Scientist  Certified Fisheries Professional  1 Smith, Chris B From: Sent: To: Subject: Page 284 of 465 Michael Donahue Monday, August 08, 2016 3:49 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 285 of 465 Thank you for the opportunity to comment. Michael Donahue shenandoah117@comcast.net 327 Blue Bird Ln Harpers Ferry, West Virginia 25425 2 Smith, Chris B From: Sent: To: Subject: Page 286 of 465 Jeff Wilson Monday, August 08, 2016 4:29 PM DEP Comments I'm the 45th signer: "Protect West Virginia Water" Dear 47CSR2 Water standards rule comments, I just signed a petition addressed to you titled Protect West Virginia Water. So far, 45 people have signed the petition. You can reach me directly by replying to this email. Or, post a response for MoveOn.org to pass along to all petition signers by clicking here: http://petitions.moveon.org/target_talkback.html?tt=tt-112579-custom73331-20260808-MPKRic The petition states: "Reject proposed weakening of WV water quality standard 47CSR2. WVDEP should: reject the “harmonic flow” estimate that would allow higher levels of carcinogenic discharges, and instead work with USGS to develop an estimate that accounts for low flow conditions; remove the change that allows a pollution permit to remove Category A drinking water designation from streams; develop a procedure that measures both Fecal Coliform and E. Coli as bacterial indicators for water recreation safety; adopt EPA’s recommended standards for aquatic life criteria; and adopt a 300 uS/cm conductivity standard to protect aquatic life from mine runoff and other threats." My additional comments are: We are led by ignorant hicks. Shame on you. To download a PDF file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838622&target_type=custom&target_id=73331 To download a CSV file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838622&target_type=custom&target_id=73331&csv=1 Jeff Wilson Morgantown, WV This email was sent through MoveOn's public petition website, a free service that allows anyone to set up their own online petition and share it with friends. MoveOn does not endorse the contents of petitions posted on our public petition website. If you have any questions, please email petitions@moveon.org. If you don't want to receive further emails updating you on how many people have signed this petition, click here: http://petitions.moveon.org/delivery_unsub.html?e=tVUo0ChI09uo.VobkFLowERFUC5Db21tZW50c0B3di5nb 3Y-&petition_id=112579. 1 Smith, Chris B From: Sent: To: Subject: Page 287 of 465 Martha Walker Monday, August 08, 2016 4:30 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 288 of 465 Thank you for the opportunity to comment. Martha Walker marthalee3@hotmail.com 202 Joseph St South Charleston, West Virginia 25303 2 Smith, Chris B From: Sent: To: Subject: Page 289 of 465 Sam Golston Monday, August 08, 2016 6:11 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 290 of 465 Thank you for the opportunity to comment. Sam Golston sam_golston@hotmail.com Sam Elkins, West Virginia 26241 2 Smith, Chris B From: Sent: To: Subject: Page 291 of 465 Richard D. Reece Monday, August 08, 2016 3:35 PM DEP Comments I'm the 39th signer: "Protect West Virginia Water" Dear 47CSR2 Water standards rule comments, I just signed a petition addressed to you titled Protect West Virginia Water. So far, 39 people have signed the petition. You can reach me directly by replying to this email. Or, post a response for MoveOn.org to pass along to all petition signers by clicking here: http://petitions.moveon.org/target_talkback.html?tt=tt-112579-custom73331-20260808-MPKRic The petition states: "Reject proposed weakening of WV water quality standard 47CSR2. WVDEP should: reject the “harmonic flow” estimate that would allow higher levels of carcinogenic discharges, and instead work with USGS to develop an estimate that accounts for low flow conditions; remove the change that allows a pollution permit to remove Category A drinking water designation from streams; develop a procedure that measures both Fecal Coliform and E. Coli as bacterial indicators for water recreation safety; adopt EPA’s recommended standards for aquatic life criteria; and adopt a 300 uS/cm conductivity standard to protect aquatic life from mine runoff and other threats." My additional comments are: Air and water are our most precious and life giving pesuxs of nature. Without them we would die. Therefore, keep them both pure as we can have them. To download a PDF file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838606&target_type=custom&target_id=73331 To download a CSV file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838606&target_type=custom&target_id=73331&csv=1 Richard D. Reece Romney, WV This email was sent through MoveOn's public petition website, a free service that allows anyone to set up their own online petition and share it with friends. MoveOn does not endorse the contents of petitions posted on our public petition website. If you have any questions, please email petitions@moveon.org. If you don't want to receive further emails updating you on how many people have signed this petition, click here: http://petitions.moveon.org/delivery_unsub.html?e=tVUo0ChI09uo.VobkFLowERFUC5Db21tZW50c0B3di5nb 3Y-&petition_id=112579. 1 Smith, Chris B From: Sent: To: Subject: Page 292 of 465 Stephanie Somers Monday, August 08, 2016 4:53 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 293 of 465 Thank you for the opportunity to comment. Stephanie Somers jhs_thespian@yahoo.com 54 Lindsey Dr Charles Town, West Virginia 25414 2 Smith, Chris B From: Sent: To: Subject: Page 294 of 465 Llysse Monday, August 08, 2016 4:57 PM DEP Comments Proposed changes to water standards: Public Comment Dear DEP: I am truly dumbfounded by the changes you're proposing. You should be at all times making the water safer for us. Why are you weakening protections? It really makes no sense given the poisoning of 300,000 people in the Charleston area, and the decades long poisoning I myself have been a victim of with c-8 in the Parkersburg area. How many people do you know who have died from kidney cancer? Zero... one? I know two *on the same street.* I nearly died from the pre-eclmapsia associated with the poisoning. Having moved away... now I have to worry about you allowing my stream to be poisoned? I will fight you tooth and nail. I have a creek on my property--beautiful little thing. Very tinkly in the spring, but it doesn't flow much in the summer. Changes to the "Critical Design Flow" are ridiculous. We have so many seasonal streams like my own. All my little fishes would die. All the crawdads. Heck, the DEER might get sick drinking from the streams if you change these standards. Don't be evil; protecting our water is not about allowing corporations to pollute us more and sicken us more in order to pad their bottom line. Our waters are a resource that should be protected for all uses. I live in rural WV, and many out here depend on non-municipal sources. Don't remove Category A designations from our streams. I'd suggest that EVERY stream should have such a designation. How can you think it's okay to designate a common resource to just the one use--someone else's waste? I know that the EPA has concluded that a simple test for electrical conductivity can show whether a stream is getting polluted from things like mining or fracking. And testing for bacteria from agricultural run-off is a good idea, too, especially in swimming holes or recreational lakes. Why not ADD a safety measure or two. You're meant to update standards to protect us, not to profit others at our expense. Don't get me wrong, I appreciate that you're wanting to adopt the EPA's recommended standards to test for those five chemicals, including carbaryl. But please, don't weaken standards elsewhere. I'm a person, dammit. It's my creek, too. I like to fish and camp, and I don't want to have to break out the map and do complex calculations to determine if it's safe to stand in the water or eat what I catch there. You know, I have health problems because of corporate bad faith and absolute disregard for the welfare of others. Don't do this to other people here in WV, too. You're here to protect us. Sincerely, Lissa Lucas Cairo, WV 26337 1 Smith, Chris B From: Sent: To: Subject: Page 295 of 465 Leslee McCarty Monday, August 08, 2016 6:10 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 296 of 465 Thank you for the opportunity to comment. Leslee McCarty lesleemac1@gmail.com 486 old Powell Rd Lewisburg, West Virginia 24901 2 Smith, Chris B From: Sent: To: Subject: Page 297 of 465 Judith Bair Monday, August 08, 2016 4:15 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 298 of 465 Thank you for the opportunity to comment. Judith Bair judithbair@gmail.com 315 Red Wing Ln. Sinks Grove, WV 24976 2 Smith, Chris B From: Sent: To: Subject: Page 299 of 465 Carol Sheffield Monday, August 08, 2016 4:55 PM DEP Comments I'm the 46th signer: "Protect West Virginia Water" Dear 47CSR2 Water standards rule comments, I just signed a petition addressed to you titled Protect West Virginia Water. So far, 46 people have signed the petition. You can reach me directly by replying to this email. Or, post a response for MoveOn.org to pass along to all petition signers by clicking here: http://petitions.moveon.org/target_talkback.html?tt=tt-112579-custom73331-20260808-MPKRic The petition states: "Reject proposed weakening of WV water quality standard 47CSR2. WVDEP should: reject the “harmonic flow” estimate that would allow higher levels of carcinogenic discharges, and instead work with USGS to develop an estimate that accounts for low flow conditions; remove the change that allows a pollution permit to remove Category A drinking water designation from streams; develop a procedure that measures both Fecal Coliform and E. Coli as bacterial indicators for water recreation safety; adopt EPA’s recommended standards for aquatic life criteria; and adopt a 300 uS/cm conductivity standard to protect aquatic life from mine runoff and other threats." My additional comments are: Just NO! Our waterways are a precious resource...FIRST, DO NO HARM!!! To download a PDF file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838634&target_type=custom&target_id=73331 To download a CSV file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838634&target_type=custom&target_id=73331&csv=1 Carol Sheffield Buckhannon, WV This email was sent through MoveOn's public petition website, a free service that allows anyone to set up their own online petition and share it with friends. MoveOn does not endorse the contents of petitions posted on our public petition website. If you have any questions, please email petitions@moveon.org. If you don't want to receive further emails updating you on how many people have signed this petition, click here: http://petitions.moveon.org/delivery_unsub.html?e=tVUo0ChI09uo.VobkFLowERFUC5Db21tZW50c0B3di5nb 3Y-&petition_id=112579. 1 Smith, Chris B From: Sent: To: Subject: Page 300 of 465 Judy Hunter Monday, August 08, 2016 7:17 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 301 of 465 Thank you for the opportunity to comment. Judy Hunter judyandcap@comcast.net 1834 Woodmont Huntington, West Virginia 25701 2 Smith, Chris B From: Sent: To: Subject: Page 302 of 465 David Fox Monday, August 08, 2016 5:54 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 303 of 465 Thank you for the opportunity to comment. David Fox lissadavidfox@gmail.com 431 Nansfield Dr HARPERS FERRY, West Virginia 25425-3161 2 Smith, Chris B From: Sent: To: Subject: Page 304 of 465 Cooper, Laura K Tuesday, August 09, 2016 10:58 AM Smith, Chris B FW: Comment on water quality standards     Laura K. Cooper  Assistant Director ‐ Water Quality Standards Division of Water and Waste Management WV Department of  Environmental Protection  Office:  304‐926‐0499 x1110  Mobile: 304‐206‐8901  Email:   Laura.K.Cooper@wv.gov  Room 2169, 601 57th St SE; Charleston, WV    ‐‐‐‐‐Original Message‐‐‐‐‐  From: Mark Blumenstein [mailto:markb@mountain.net]  Sent: Tuesday, August 09, 2016 7:31 AM  To: Cooper, Laura K  Subject: Comment on water quality standards     The WV Rivers Coalition has covered the extremely technical aspect of protecting our life source , WATER and I agree .  What our State needs  ,is to lead the way and not follow . We are the headwaters to surrounding states and how many  millions of citizens and yet we continue to turn our heads where serious pollutants are pumped into our ground and  then we find out months down the road contaminants in our water supply I.e. Lockjelly injection well for an example .  We allow fracking which is contaminating entire regions of subgeo strata , just waiting for these highly toxic chemicals to  appear miles from the injection source . Then trying to identify the impossible source of these leaks in the substrata . We  know this happens and we know that our waters are threatened !  Just look at the surrounding health of that community's not the rim of the New River Gorge  . This goes directly to water  quality standards. You must consider and question practices and methods of disposal ! You must consider oversight!   You must consider the health of your community . Setting standards must go hand in hand with oversight . Killing our  citizens slowly with poorly regulated waters with chemical contamination that is not regulated for, will cause mass   extinction . You can see it now in the numbers of cancer cases in our state !  Fix this issue now before it's too late Mark Blumenstein , past president and board member of Greenbrier River  Watershed Assoc. and Friends of the Lower Greenbrier River.  365  Sky View Farm Lane  ALDERSON WV 24910       Sent from my iPad  1 Smith, Chris B From: Sent: To: Subject: Page 305 of 465 Cooper, Laura K Tuesday, August 09, 2016 10:58 AM Smith, Chris B FW: Comment re: WQS Triennial Review proposed standards     Laura K. Cooper Assistant Director - Water Quality Standards Division of Water and Waste Management  WV Department of Environmental Protection   Office: 304-926-0499 x1110   Mobile: 304-206-8901  Email: Laura.K.Cooper@wv.gov Room 2169, 601 57th St SE; Charleston, WV   From: Robin Blakeman [mailto:rbrobinjh@gmail.com]   Sent: Monday, August 08, 2016 4:48 PM  To: Cooper, Laura K  Subject: Comment re: WQS Triennial Review proposed standards  Please see our (OVEC) comments below and include them in your public record for the 8/9 scheduled public meeting. Thanks for taking our concerns into consideration! Ohio Valley Environmental Coalition comments: August 8, 2016 Laura Cooper 601 57th St SE Charleston, WV 25304 1 Page 306 of 465 Dear Ms. Cooper: Comment Re: Triennial review proposed amendments to existing water quality standards We join with many of our allies, including WV Rivers Coalition, to strongly oppose these proposed rule changes. We oppose any weakening of the Category A classification for our potential (future) or actual (current) source water streams. We also oppose changing the stream flows used in pollution limit calculations from one using low-flow conditions to one using average flow; this is an action that even agency officials acknowledge allows greater levels of cancer-causing chemicals to flow into our streams and rivers. WV already has some of the highest cancer rates in the nation, according to the Center for Disease Control (CDC): http://www.cdc.gov/cancer/dcpc/data/state.htm. Given this, it seems imperative to tighten regulations on known or potentially carcinogenic chemical releases, and to fully enforce those regulations throughout our state using every regulatory tool at our disposal. This is not the direction the DEP seems to be moving with these proposed rule changes. As DEP officials have admitted, there is great uncertainty about how much more chemicals would be allowed into our streams with these rule changes. A study to assess this potential and to survey exactly what kinds of chemicals would be added in greater quantities to our streams should be done prior to any further consideration of these rule changes. The data from this study should be put into an accessible public record. Also, a geological survey must be carried out to accurately assess the correct calculations for a so-called “harmonic mean.” Again, we are strongly opposed to a transition to use of the harmonic mean standard from the low-flow standards. This proposed rule change seems to clearly preference industry demands over human health, which seems strongly in opposition with the published mission of the WV DEP to “promote a healthy environment” presumably for the citizens and communities of WV. On the subject of bacteria, we support DEP’s recommendation to utilize the E. coli standards, but would encourage establishment of monthly testing procedures to adequately monitor our streams for that pollutant. We also encourage frequent sampling and monitoring for both E. coli and fecal coliform indicators during the transition period while these standards are being implemented, to ensure that our streams are safe for recreational use. Thanks for considering these comments and adding them to your public record regarding these issues. Sincerely, Robin Blakeman, Ohio Valley Environmental Coalition 2 Smith, Chris B From: Sent: To: Subject: Page 307 of 465 Cooper, Laura K Tuesday, August 09, 2016 11:00 AM Smith, Chris B FW: 62 signers: Protect West Virginia Water petition     Laura K. Cooper Assistant Director - Water Quality Standards Division of Water and Waste Management  WV Department of Environmental Protection   Office: 304-926-0499 x1110   Mobile: 304-206-8901  Email: Laura.K.Cooper@wv.gov Room 2169, 601 57th St SE; Charleston, WV   From: Vernon Haltom [mailto:petitions@moveon.org]   Sent: Monday, August 08, 2016 9:18 PM  To: Cooper, Laura K  Subject: 62 signers: Protect West Virginia Water petition  Dear Laura Cooper, I started a petition to you titled Protect West Virginia Water. So far, the petition has 62 total signers. You can post a response for us to pass along to all petition signers by clicking here: http://petitions.moveon.org/target_talkback.html?tt=tt-112579-custom-73330-20260808-sUj5cm The petition states: "Reject proposed weakening of WV water quality standard 47CSR2. WVDEP should: reject the “harmonic flow” estimate that would allow higher levels of carcinogenic discharges, and instead work with USGS to develop an estimate that accounts for low flow conditions; remove the change that allows a pollution permit to remove Category A drinking water designation from streams; develop a procedure that measures both Fecal Coliform and E. Coli as bacterial indicators for water recreation safety; adopt EPA’s recommended standards for aquatic life criteria; and adopt a 300 uS/cm conductivity standard to protect aquatic life from mine runoff and other threats." To download a PDF file of all your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838693&target_type=custom&target_id=73330 To download a CSV file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838693&target_type=custom&target_id=73330&csv=1 Thank you. --Vernon Haltom 1 Page 308 of 465 If you have any other questions, please email petitions@moveon.org. The links to download the petition as a PDF and to respond to all of your constituents will remain available for the next 14 days. This email was sent through MoveOn's petition website, a free service that allows anyone to set up their own online petition and share it with friends. MoveOn does not endorse the contents of petitions posted on our public petition website. If you don't want to receive further emails updating you on how many people have signed this petition, click here: http://petitions.moveon.org/delivery_unsub.html?e=n_gEeZd8232FwN6IAqruekxhdXJhLksuQ29vcGVyQHd2L mdvdg--&petition_id=112579. 2 Page 309 of 465 WVRWA Comments on WV Water Quality Standards (8/8/16): These comments are made in addition to WVRWA’s previous comments to WV Division of Environmental Protection, regarding WVDEP’s Triennial Review of its Water Quality Standards. These comments are in regard to estimating stream flow for ungauged streams, and the uncertainty in those estimates. WVDEP proposes changes in the critical design flow for permitted dischargers, specifically changing 47CSR2 Section 8.2.b, to allow for use of the Harmonic Mean Low Flow for discharges of carcinogens and 30Q5 Low Flow for non-carcinogens, rather than the currently used 7Q10 Low Flow. These changes would allow for significantly greater loads of such pollutants being discharged, as Harmonic Mean and 30Q5 flows are significantly greater than 7Q10. This point was debated in the 1990s, and 7Q10 flow was kept as the critical design flow. Part of the debate in the past dealt with the potential inaccuracy of 7Q10 low flows for locations where actual flow measurements don’t exist, and the need for better low flow data. In recent years the US Geological Survey has published several studies of streamflow in West Virginia, including regression equations for estimating low flows at unmeasured locations throughout the state. WVDEP has a webpage where a map of the state can be queried to find the flow statistics for such locations, using the USGS historical data for gauged locations and the regression equations for ungauged locations. The low flow values estimated by these equations are only approximations, with the resulting values for Harmonic Mean, 30Q5 and 7Q10 calculated for the gauged locations being as much as 3 times more or less the historic record. As an alternative to using the USGS regression equations, WVRWA recommends WVDEP consider a mapping method for estimating low flow values between gauging stations. To visualize the mapping, first consider that WVDEP’s Water Use Section has a map layer for Average Annual Precipitation, which is a variable in some of the USGS equations. In WV, we average between 2 and 5 feet of precipitation per year, with the lowest values along the Ohio River, in the Southern Coalfields and in the Eastern Panhandle. The wettest part of the state is in the east central highlands, where the highest mountains capture more of the west-east flows of moisture. WVDEP could easily add another mapping layer that could be of more value to the Water Use Section, which would be a map of the Average Annual Runoff across the state. Statewide, Average Annual Runoff is generally about 2 feet per year less than Average Annual Precipitation, with the difference being what is lost to Evapotranspiration. All three of these variables could be mapped, either as inches per year, or as cubic feet per second per square mile (cfsm). (one cfsm = 13.6 inches/yr) Low flow statistics, such as Harmonic Mean, 30Q5 and 7Q10, could also be mapped as cfsm, or as % of Average Annual Runoff, using values for gauged locations. Low flow statistics (as cfsm or % of AAR) for locations between gauging stations could be contoured, and then low flow flows in cfs calculated for a watershed from its area in square miles. Page 310 of 465 One advantage to such mapping of contoured flow statistics could be the added insights gained from visualizing the data. For example, low flows tend to be a higher % of Annual Runoff in the karst and pseudo-karst (deep mined) watersheds, as well as in watersheds with above ground reservoirs. The effect on low flows from other watershed variables, such as soil type or soil organic carbon content, % impervious surfaces, etc may also become apparent. A key advantage for WVDEP’s Water and Wastewater Permitting Section from mapping low flow data in this way could be a reduction of the uncertainty in the flow values relative to the uncertainty in values from the regression equations. WVDEP should assess this possibility. In addition, WVDEP should maintain a policy of promoting the collection of streamflow data where it is currently lacking, which will help validate low flow data for such locations. For example, if a party were to question the low flow value being estimated for an ungauged location, WVDEP may promote the collection of flow data at or near that location by the interested party and/or other stakeholders. If a permit applicant were to begin collecting flow data on a previously ungauged stream, and had a year’s worth of data for example, could this be sufficient data to amend a previous low flow statistic which was based solely on data from other sites? Perhaps WVDEP could include a measure of uncertainty (a “margin of safety”) in its low flow statistics for ungauged locations. If the margin of safety, for example, made for a critical design flow 100 cfs instead of an otherwise estimated 500 cfs, but the permitee could get a critical design flow of 500 cfs (or potentially much more) by collecting sufficient local stream flow data, the permitee would have an incentive to collect the flow data. http://petitions.moveon.org/delivery_unsub.html?e=n_gEeZd8232FwN6IAqruekxhdXJhLksuQ29vcGVyQHd2L Page 311 of 465 mdvdg--&petition_id=112579. 2 Smith, Chris B From: Sent: To: Subject: Page 312 of 465 ann malone Monday, August 08, 2016 8:09 PM Cooper, Laura K I'm the 55th signer: "Protect West Virginia Water" Dear Laura Cooper, I just signed a petition addressed to you titled Protect West Virginia Water. So far, 55 people have signed the petition. You can reach me directly by replying to this email. Or, post a response for MoveOn.org to pass along to all petition signers by clicking here: http://petitions.moveon.org/target_talkback.html?tt=tt-112579-custom73330-20260808-sUj5cm The petition states: "Reject proposed weakening of WV water quality standard 47CSR2. WVDEP should: reject the “harmonic flow” estimate that would allow higher levels of carcinogenic discharges, and instead work with USGS to develop an estimate that accounts for low flow conditions; remove the change that allows a pollution permit to remove Category A drinking water designation from streams; develop a procedure that measures both Fecal Coliform and E. Coli as bacterial indicators for water recreation safety; adopt EPA’s recommended standards for aquatic life criteria; and adopt a 300 uS/cm conductivity standard to protect aquatic life from mine runoff and other threats." My additional comments are: People's health should be more important than corporate profit! To download a PDF file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838670&target_type=custom&target_id=73330 To download a CSV file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838670&target_type=custom&target_id=73330&csv=1 ann malone sugar grove, VA This email was sent through MoveOn's public petition website, a free service that allows anyone to set up their own online petition and share it with friends. MoveOn does not endorse the contents of petitions posted on our public petition website. If you have any questions, please email petitions@moveon.org. If you don't want to receive further emails updating you on how many people have signed this petition, click here: http://petitions.moveon.org/delivery_unsub.html?e=n_gEeZd8232FwN6IAqruekxhdXJhLksuQ29vcGVyQHd2L mdvdg--&petition_id=112579. 1 Smith, Chris B From: Sent: To: Subject: Page 313 of 465 Tom Ferguson Monday, August 08, 2016 7:51 PM Cooper, Laura K I'm the 54th signer: "Protect West Virginia Water" Dear Laura Cooper, I just signed a petition addressed to you titled Protect West Virginia Water. So far, 54 people have signed the petition. You can reach me directly by replying to this email. Or, post a response for MoveOn.org to pass along to all petition signers by clicking here: http://petitions.moveon.org/target_talkback.html?tt=tt-112579-custom73330-20260808-sUj5cm The petition states: "Reject proposed weakening of WV water quality standard 47CSR2. WVDEP should: reject the “harmonic flow” estimate that would allow higher levels of carcinogenic discharges, and instead work with USGS to develop an estimate that accounts for low flow conditions; remove the change that allows a pollution permit to remove Category A drinking water designation from streams; develop a procedure that measures both Fecal Coliform and E. Coli as bacterial indicators for water recreation safety; adopt EPA’s recommended standards for aquatic life criteria; and adopt a 300 uS/cm conductivity standard to protect aquatic life from mine runoff and other threats." My additional comments are: We all live downstream .Headwater streams are where pure water is made. Clean water is our most valuable resource! To download a PDF file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838664&target_type=custom&target_id=73330 To download a CSV file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838664&target_type=custom&target_id=73330&csv=1 Tom Ferguson Mesa, AZ This email was sent through MoveOn's public petition website, a free service that allows anyone to set up their own online petition and share it with friends. MoveOn does not endorse the contents of petitions posted on our public petition website. If you have any questions, please email petitions@moveon.org. If you don't want to receive further emails updating you on how many people have signed this petition, click here: http://petitions.moveon.org/delivery_unsub.html?e=n_gEeZd8232FwN6IAqruekxhdXJhLksuQ29vcGVyQHd2L mdvdg--&petition_id=112579. 1 Smith, Chris B From: Sent: To: Subject: Page 314 of 465 Michael A. Moore Monday, August 08, 2016 7:31 PM Cooper, Laura K I'm the 51st signer: "Protect West Virginia Water" Dear Laura Cooper, I just signed a petition addressed to you titled Protect West Virginia Water. So far, 52 people have signed the petition. You can reach me directly by replying to this email. Or, post a response for MoveOn.org to pass along to all petition signers by clicking here: http://petitions.moveon.org/target_talkback.html?tt=tt-112579-custom73330-20260808-sUj5cm The petition states: "Reject proposed weakening of WV water quality standard 47CSR2. WVDEP should: reject the “harmonic flow” estimate that would allow higher levels of carcinogenic discharges, and instead work with USGS to develop an estimate that accounts for low flow conditions; remove the change that allows a pollution permit to remove Category A drinking water designation from streams; develop a procedure that measures both Fecal Coliform and E. Coli as bacterial indicators for water recreation safety; adopt EPA’s recommended standards for aquatic life criteria; and adopt a 300 uS/cm conductivity standard to protect aquatic life from mine runoff and other threats." My additional comments are: Yeah. I agree that more corporations should make more insane amounts of money off of polluting our natural resources, while we are left with nothint when their toxic resources spill over into our water because they dont actually care sbout standards. And i think its great that no one is ever held accountable. We should not be allowing more pillutants, and more streams desecrated. We should ve cutting back and attempting to fix the streams that are damaged. To download a PDF file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838655&target_type=custom&target_id=73330 To download a CSV file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838655&target_type=custom&target_id=73330&csv=1 Michael A. Moore Charleston, WV This email was sent through MoveOn's public petition website, a free service that allows anyone to set up their own online petition and share it with friends. MoveOn does not endorse the contents of petitions posted on our public petition website. If you have any questions, please email petitions@moveon.org. If you don't want to 1 receive further emails updating you on how many people signed this petition, click here: Page 315have of 465 http://petitions.moveon.org/delivery_unsub.html?e=n_gEeZd8232FwN6IAqruekxhdXJhLksuQ29vcGVyQHd2L mdvdg--&petition_id=112579. 2 Smith, Chris B From: Sent: To: Subject: Page 316 of 465 Daile Boulis Monday, August 08, 2016 8:59 PM Cooper, Laura K I'm the 60th signer: "Protect West Virginia Water" Dear Laura Cooper, I just signed a petition addressed to you titled Protect West Virginia Water. So far, 60 people have signed the petition. You can reach me directly by replying to this email. Or, post a response for MoveOn.org to pass along to all petition signers by clicking here: http://petitions.moveon.org/target_talkback.html?tt=tt-112579-custom73330-20260808-sUj5cm The petition states: "Reject proposed weakening of WV water quality standard 47CSR2. WVDEP should: reject the “harmonic flow” estimate that would allow higher levels of carcinogenic discharges, and instead work with USGS to develop an estimate that accounts for low flow conditions; remove the change that allows a pollution permit to remove Category A drinking water designation from streams; develop a procedure that measures both Fecal Coliform and E. Coli as bacterial indicators for water recreation safety; adopt EPA’s recommended standards for aquatic life criteria; and adopt a 300 uS/cm conductivity standard to protect aquatic life from mine runoff and other threats." My additional comments are: WVDEP has a poor track record using "estimates". The water quality standards should not change until a true study has been completed. To download a PDF file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838686&target_type=custom&target_id=73330 To download a CSV file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838686&target_type=custom&target_id=73330&csv=1 Daile Boulis Charleston, WV This email was sent through MoveOn's public petition website, a free service that allows anyone to set up their own online petition and share it with friends. MoveOn does not endorse the contents of petitions posted on our public petition website. If you have any questions, please email petitions@moveon.org. If you don't want to receive further emails updating you on how many people have signed this petition, click here: http://petitions.moveon.org/delivery_unsub.html?e=n_gEeZd8232FwN6IAqruekxhdXJhLksuQ29vcGVyQHd2L mdvdg--&petition_id=112579. 1 Smith, Chris B From: Sent: To: Subject: Page 317 of 465 Jennifer Lee Monday, August 08, 2016 7:49 PM Cooper, Laura K I'm the 53rd signer: "Protect West Virginia Water" Dear Laura Cooper, I just signed a petition addressed to you titled Protect West Virginia Water. So far, 53 people have signed the petition. You can reach me directly by replying to this email. Or, post a response for MoveOn.org to pass along to all petition signers by clicking here: http://petitions.moveon.org/target_talkback.html?tt=tt-112579-custom73330-20260808-sUj5cm The petition states: "Reject proposed weakening of WV water quality standard 47CSR2. WVDEP should: reject the “harmonic flow” estimate that would allow higher levels of carcinogenic discharges, and instead work with USGS to develop an estimate that accounts for low flow conditions; remove the change that allows a pollution permit to remove Category A drinking water designation from streams; develop a procedure that measures both Fecal Coliform and E. Coli as bacterial indicators for water recreation safety; adopt EPA’s recommended standards for aquatic life criteria; and adopt a 300 uS/cm conductivity standard to protect aquatic life from mine runoff and other threats." My additional comments are: What's in this for us? This change would be a real step backward. It's a betrayal of the many to benefit the few. To download a PDF file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838661&target_type=custom&target_id=73330 To download a CSV file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838661&target_type=custom&target_id=73330&csv=1 Jennifer Lee Parkersburg, WV This email was sent through MoveOn's public petition website, a free service that allows anyone to set up their own online petition and share it with friends. MoveOn does not endorse the contents of petitions posted on our public petition website. If you have any questions, please email petitions@moveon.org. If you don't want to receive further emails updating you on how many people have signed this petition, click here: http://petitions.moveon.org/delivery_unsub.html?e=n_gEeZd8232FwN6IAqruekxhdXJhLksuQ29vcGVyQHd2L mdvdg--&petition_id=112579. 1 Smith, Chris B From: Sent: To: Subject: Page 318 of 465 Jessica Blalock Monday, August 08, 2016 9:18 PM Cooper, Laura K I'm the 61st signer: "Protect West Virginia Water" Dear Laura Cooper, I just signed a petition addressed to you titled Protect West Virginia Water. So far, 62 people have signed the petition. You can reach me directly by replying to this email. Or, post a response for MoveOn.org to pass along to all petition signers by clicking here: http://petitions.moveon.org/target_talkback.html?tt=tt-112579-custom73330-20260808-sUj5cm The petition states: "Reject proposed weakening of WV water quality standard 47CSR2. WVDEP should: reject the “harmonic flow” estimate that would allow higher levels of carcinogenic discharges, and instead work with USGS to develop an estimate that accounts for low flow conditions; remove the change that allows a pollution permit to remove Category A drinking water designation from streams; develop a procedure that measures both Fecal Coliform and E. Coli as bacterial indicators for water recreation safety; adopt EPA’s recommended standards for aquatic life criteria; and adopt a 300 uS/cm conductivity standard to protect aquatic life from mine runoff and other threats." My additional comments are: We need to find better ways to protect our water! To download a PDF file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838692&target_type=custom&target_id=73330 To download a CSV file of all of your constituents who have signed the petition, including their addresses, click this link: http://petitions.moveon.org/deliver_pdf.html?job_id=1838692&target_type=custom&target_id=73330&csv=1 Jessica Blalock Charleston, WV This email was sent through MoveOn's public petition website, a free service that allows anyone to set up their own online petition and share it with friends. MoveOn does not endorse the contents of petitions posted on our public petition website. If you have any questions, please email petitions@moveon.org. If you don't want to receive further emails updating you on how many people have signed this petition, click here: http://petitions.moveon.org/delivery_unsub.html?e=n_gEeZd8232FwN6IAqruekxhdXJhLksuQ29vcGVyQHd2L mdvdg--&petition_id=112579. 1 Smith, Chris B From: Sent: To: Subject: Page 319 of 465 Ashofteh Bouman Tuesday, August 09, 2016 1:40 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 320 of 465 Thank you for the opportunity to comment. Ashofteh Bouman ashbouman@hotmail.com 282 Ashwood Dr. Meadow Bridge , West Virginia 25976 2 Smith, Chris B From: Sent: To: Subject: Page 321 of 465 Shantha Alonso Tuesday, August 09, 2016 12:53 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 322 of 465 Thank you for the opportunity to comment. Shantha Alonso shantha@creationjustice.org 9901 Woodland Dr. Silver Spring, Maryland 20902 2 Smith, Chris B From: Sent: To: Subject: Page 323 of 465 Taylor Johnson Tuesday, August 09, 2016 12:27 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Please protect our water, do not weaken our water protect. Please adopt the following standards. Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. 1 Page 324 of 465 Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. Taylor Johnson taylorj24945@gmail.com 3227 Ellison Rdg Greenville, Colorado WV 24945 2 Smith, Chris B From: Sent: To: Subject: Page 325 of 465 Leslie Stone Tuesday, August 09, 2016 11:55 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water is the world's most precious and vital resource. We are blessed with an abundance in WV. At all costs, for both human life and the state's economy, we must protect and preserve our water. Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. 1 Page 326 of 465 Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. Leslie Stone leslie.stone4@gmail.com 5294 DeWitt Road Charleston , West Virginia 25314 2 Smith, Chris B From: Sent: To: Subject: Page 327 of 465 Selina Vickers Tuesday, August 09, 2016 1:41 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water standards need to be very strict! We all need water. Do everything to protect our water, please! Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. 1 Page 328 of 465 Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. Selina Vickers emailtheselina@gmail.com 2821 Lansing Edmond Rd Edmond, West Virginia 25837 2 Page 329 of 465 Smith, Chris B From: Sent: To: Subject: Diane Wellman Tuesday, August 09, 2016 12:47 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, It's crazy that a letter like this needs to be written at all, given that 300,000 people had their drinking water contaminated due to lax laws and lax oversight. We need stricter laws to protect our water, not weaker. Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. 1 Page 330 of 465 Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. Diane Wellman dwellwv@comcast.net PO Box 2546 Huntington, West Virginia 25726 2 Smith, Chris B From: Sent: To: Subject: Page 331 of 465 Rachelle Marion Tuesday, August 09, 2016 12:21 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 332 of 465 Thank you for the opportunity to comment. Rachelle Marion rachelle304@gmail.com 836 White Oak Hgts Elkview, West Virginia 25071 2 Smith, Chris B From: Sent: To: Subject: Page 333 of 465 Dwayne Milam Tuesday, August 09, 2016 11:49 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, As a resident of Summers County, I am writing today to express my concern regarding water quality in my county, and within our state. Unfortunately our county, and farm lies within the path of the proposed Mountain Valley Pipeline (MVP). Almost everyone in rural areas rely on wells and springs for water. Massive construction and blasting in the vicinity of wells and springs will likely negatively effect our water supply. Runoff from construction will also negatively impact our water. As you know our mountains are very steep and the soil is very close to bedrock...we get large quantities of rain from micro-bursts, hurricanes and strong thunderstorms (as the destruction in Greenbrier and Summers County has recently shown). As this rain was falling, I thought that we are very fortunate that the MVP had not been constructed. You and I both know what would have happened...all of the dirt would have washed away and eventually ended-up in our streams and rivers. Our wells would likely had been contaminated in addition to various public water supplies. Protect our water, strengthen the rules and regulations that safeguard all of the citizens of West Virginia. Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. 1 Page 334 of 465 Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. Sincerely, Dwayne Milam Dwayne Milam dlmilam2010@hotmail.com 418 Doc Miller Lane Alderson, West Virginia 24910 2 Smith, Chris B From: Sent: To: Subject: Page 335 of 465 Natalie Thiele Tuesday, August 09, 2016 1:40 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, I am very concerned about the possibility that West Virginia water quality standards may soon be undermined instead of upheld or strengthened. My family drinks West Virginia water, bathes in it, and all the produce we grow and eat has been watered with it-- and I would like our municipal water source (a West Virginia river) to remain as clean and safe as it currently is, if not cleaner and safer. All West Virginians have a right to clean and safe drinking water and access to clean recreational bodies of water, and I hope that the WVDEP does their part to help protect that right. Thank you for your advocacy. What follows is the suggested letter from the West Virginia Rivers Coalition: Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. 1 Page 336 of 465 Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. Natalie Thiele natalie.a.a.thiele@gmail.com 905 Walnut St Glenville, West Virginia 26351 2 Smith, Chris B From: Sent: To: Subject: Page 337 of 465 Amy Gherke Tuesday, August 09, 2016 12:43 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, WV is known for her beautiful land, rivers, streams, and mountains. Please help keep our water clean. Actually, please do not allow any more pollution into our waters. We are made primarily of water, so when our sources become polluted, so do our bodies. -Amy S. Gherke Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. 1 Page 338 of 465 Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. Amy Gherke amysue913@yahoo.com 2088 Atkinson Ridge Rd Walker, West Virginia 26180 2 Smith, Chris B From: Sent: To: Subject: Page 339 of 465 Cindy Smith Tuesday, August 09, 2016 12:06 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 340 of 465 Thank you for the opportunity to comment. Cindy Smith buz.cindy.smith@gmail.com 3808 Wash Ave SE CHARLESTON , West Virginia 25304 2 Smith, Chris B From: Sent: To: Subject: Page 341 of 465 Sara Young Tuesday, August 09, 2016 11:39 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. 1 Page 342 of 465 Sincerely, Sara Young Sara Young syoung1145@yahoo.com 112 Airview Lane Craigsville, West Virginia 26205 2 Page 343 of 465 Smith, Chris B From: Sent: To: Subject: Donald Briggs Tuesday, August 09, 2016 12:57 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Please do not sacrifice our public health and outdoor recreation-based economy; I urge you to: - Remove the provision to allow Category A use change through a NPDES permit which is contrary to the Clean Water Act. - Conduct a statewide study in collaboration with USGS to determine the best estimates for flow taking into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances. - Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation— this is important to maintain the health of our outdoor recreation economy as well as our drinking and fishing waters. - Adopt as proposed EPA’s recommended standards for aquatic life criteria for acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. Donald Briggs 1donaldbriggs@gmail.com P. O. Box 733 Shepherdstown, West Virginia 25443 1 Smith, Chris B From: Sent: To: Subject: Page 344 of 465 Damon Mills Tuesday, August 09, 2016 12:28 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 345 of 465 Thank you for the opportunity to comment. Damon Mills five5tbird@aol.com 338 11th ave west Huntington , West Virginia 25701 2 Smith, Chris B From: Sent: To: Subject: Page 346 of 465 Bonnie Hall Tuesday, August 09, 2016 12:01 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 347 of 465 Thank you for the opportunity to comment. Bonnie Hall bhall42@live.com 164 Allen Ridge Road New Martinsville, West Virginia 26155 2 Smith, Chris B From: Sent: To: Subject: Page 348 of 465 Sharon Kearns Tuesday, August 09, 2016 11:34 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, I agree with the following below but want to insert my own comments, too. I have a farm in Hillsboro but my permanent home is in Virginia so I can easily contrast some of what I experience in both states. Virginia tries to listen to its' people and is not as easily influenced by corporations that don't have the interests of their people in mind. I see the proposed changes as an effort to weaken the rights of West Virginians to have clean drinkable water. Hillsboro, where I have a farm, has wonderful water. I tested the water before we bought our farm and those results and our soils are exactly the reason we are in WV. Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. 1 Page 349 of 465 Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. Please consider the people of West Virginia before you allow the weakening of water standards. Thank you for your service, Sincerely, Sharon Kearns Sharon Kearns skwalks@gmail.com 110 Kestrel Lane Hillsboro, West Virginia 24946 2 Page 350 of 465 Comments of the West Virginia Manufacturers Association regarding the Requirements Governing Water Quality Standards 47 CSR 2 These comments are filed on behalf of the West Virginia Manufacturers Association (WVMA) on the proposed rule titled “Requirements Governing Water Quality Standards,” 47 C.S.R. 2 (the Proposed Rule). Formed in 1915, the WVMA represents the interests of manufacturers throughout West Virginia. The WVMA promotes balancing environmental protection and economic development in order to provide safe and productive opportunities for citizens of the state of West Virginia. Our members have a tradition of technological innovation and providing jobs for West Virginians. Moreover, the WVMA has experience working with environmental regulators and community members in order to protect the environment and promote economic development. It is in this spirit of experience and partnership that the WVMA offers these comments. A. The Category A Public Water Use Definition Should Be Re-Evaluated and Revised During the 2015 Legislative Session the approval of revisions to water quality standards in HB 2283 was conditioned on a study by the Department of Environmental Protection (DEP) of the possible alternative application of the Category A public water supply use described in 47 CSR 2-6.2 (the Category A use): (h) The legislative rule filed in the State Register on August 1, 2014, authorized under the authority of section four, article eleven, chapter twenty-two of this code, relating to the Department of Environmental Protection (requirements governing water quality standards, 47 CSR 2), is authorized.; Provided; that the Secretary of the Department of Environmental Protection shall consider, for the 2017 triennial review, potential alternative applications for the Category A drinking water use designation to the waters of the state, taking into consideration stream flow, depth, and distance to a public water intake. 1 Page 351 of 465 Currently, the DEP applies Category A criteria in all locations in all state waterbodies, even where the water is not being used as a public water supply. The study mandated by the Legislature presented an opportunity for the DEP to reconsider its application of the Category A use, by exploring the function of the Category A use and how alternatives to the DEP’s present approach might provide relief to industry without affecting public protections. Instead, the DEP has proposed a very convoluted procedure that would only apply to water bodies that, by their very description, are not feasible as public water supplies. The DEP gave no consideration to how industry might have demonstrated, during the permit process, that existing public water supply intakes were too far away to be affected by an industrial or municipal discharge. We are very disappointed that the DEP ignored the Legislature’s direction and refused to consider whether distance to intake should be evaluated when determining where the Category A use applies. The reason the DEP has given for refusing to allow relief from Category A criteria is that W. Va. Code §22-11-7b(c) obligates the agency to protect future uses, and that it must apply Category A in all streams so that all of them are available as future drinking water supplies. That interpretation of the DEP’s authority represents a selective reading of the statute. The relevant sentence provides that: Standards of quality with respect to surface waters shall protect the public health and welfare, wildlife, fish and aquatic life and the present and prospective future uses of the water for domestic, agricultural, industrial, recreational, scenic and other legitimate beneficial uses thereof. In the hierarchy of considerations set forth in that sentence, domestic use of water resources is not afforded pre-eminence over the need to foster industrial growth in West Virginia. To imply, as the DEP does with its interpretation of the statute, that it need give no consideration to future industrial growth when applying water quality standards, is disturbing. 2 Page 352 of 465 The WVMA is not suggesting that public water supplies are not deserving of protection; it would merely point out that those protections already exist, and will remain in place, even if the changes that it has proposed are implemented. First, a drinking water use has priority of right. If a public water supply decides to put its intake 10 feet downstream of an existing industrial or municipal discharge, the drinking water use becomes an existing use, and Category A criteria must be met. In that situation, the DEP will set limits on upstream dischargers to protect the new intake. Second, the number of new intakes that have been proposed in the state over the past few years has been vanishingly small, and there have been no siting disputes between industrial and potable water uses. Both domestic and industrial uses can be accommodated. Third, the DEP is essentially prohibiting development in the state by any new manufacturer or other business that might discharge Category A pollutants above criteria levels. There is no difference between existing dischargers asking for minor relief from strict Category A criteria-based permit limits for their discharges, and new dischargers who will need a mixing zone to meet Category A-based permit limits. Both are, in the DEP’s view, preventing future use of a stream segment as a public water supply. Accordingly, we can only conclude that the DEP will not permit any new discharger, if it would need a Category A mixing zone, because that would mean that limited area is no longer available for use as a public water supply. The WVMA had proposed to the DEP that we set aside years of arguing over whether the Category A use is intended to apply in all locations, in all state streams, and instead develop a system that allows dischargers to demonstrate, by modeling or otherwise, that no one downstream of their intakes would be affected by Category A pollutants, in which case the Category A criteria would not apply to that discharger. That is, after all, what someone would demonstrate if he or she wanted to remove the Category A use from a stream segment, and by 3 Page 353 of 465 following the WVMA’s suggested approach, the permittee would not waste tens of thousands of dollars in consultant and legal fees, and lose at least a year or two seeking approval from the DEP, the Legislature, and the EPA. We know that such a system would work, because the mining industry does it right now, in order to avoid stringent Category A limits for manganese. Mines that are seeking relief from the Category A criteria for manganese survey the area 5 miles downstream of their discharges, to determine whether there are any public or private intakes. If there are not any intakes, the stricter Category A manganese criteria do not apply. If there are intakes in that stream segment, the mine has to meet the Category A criteria. Rather than take this sort of common sense approach, the DEP proposes a cumbersome process that allows only limited relief, and only for those streams with insufficient flow or a hydrologic modification. Even then, the relief would not be available if “insufficient flow may be compensated for by the discharge of sufficient volume of effluent discharges” or “reasonable provision for storage or impoundment of the water could be made” or if the stream may be capable of serving as an emergency water supply. 47 CSR. § 2.6.3.a.. Even if that hurdle is crossed, the permittee would be required to provide the same information that is mandated for a use removal or other change, such as a description of general land use in the area and an assessment of aquatic life, even though that information is irrelevant to removal of a drinking water use. The proposed rule goes on to require that EPA approve the determination that Category A does not apply, despite the fact that EPA does not have that authority in this sort of permitting situation. In evaluating how the Category A use should be applied, the DEP should have looked at how the use was originally meant to be interpreted. The Category A use was never intended to apply in all places state-wide. When the Water Resources Board, the entity that formerly 4 Page 354 of 465 developed water quality standards, adopted the Category A definition, it said in its response to comments about this section that: The Board responded to the first group of comments [relating to the types of water intakes that would be protected] by agreeing that all waters actually used for human consumption should be included in the definition and therefore protected. They further agreed that defining where the criteria are to apply as part of the definition might be improper. Above all, they agreed that the category and criteria for public water supplies should not be applied to streams or stream segments where no one is using the waters for drinking. State Water Resources Board of West Virginia Rationale Document for Revision of Legislative Rules Series I, II, III and IX (January 6, 1986) at 19-20 (bold emphasis added). The Board never meant for the Category A use to apply where there was no public drinking water intake. A review of the rule, and the observations of the Board that adopted the rule, clearly establish that the goal is to protect public drinking water that is drawn through surface water intakes and subjected to conventional treatment (e.g., settling, clarification, chlorination).1 The water that is drawn into those intakes must meet human health criteria. As long as the water meets those criteria, the water quality standards are being properly applied. Imposing the Category A use in all locations in the state, regardless of actual use, is inconsistent with the requirement in the Code that DEP rules adopted after July 1, 1994 cannot be more stringent than a counterpart federal program without a written demonstration that such additional stringency is needed “to protect, preserve or enhance the quality of West Virginia’s environment or human health or safety, taking into consideration the scientific evidence, specific environmental characteristic of West Virginia or an area thereof . . .” W. Va. Code §22-1-3a. We know the DEP’s position is more stringent than required by the federal water quality standards program because neighboring states with EPA-approved water quality standards do not 1 “’Conventional treatment’ is the treatment of water as approved by the West Virginia Bureau for Public Health to assure that the water is safe for consumption.” 47 CSR 2-2.1. 5 Page 355 of 465 treat every waterbody as a public water supply. Maryland, Kentucky, Ohio and Virginia all limit Category A-equivalent protections to those areas where public water supplies might actually be affected. There is no reason for West Virginia to be more exacting than neighboring states, and more stringent than federal requirements. The WVMA proposes the following as a more appropriate revision to 47 CSR 2-6.3, in lieu of the DEP’s proposal: For purposes of setting limits in permits, the Category A criteria in Appendix E and human health narrative criteria for drinking water developed pursuant to Section 3 of this rule shall apply at the point of discharge (subject to any mixing zone developed in accordance with Section 5) unless the permittee demonstrates that there is no public water supply intake that would be affected by the discharge. A public water supply intake is affected by a permittee’s discharge when substances discharged by the permittee would exceed the criteria in Appendix E, or any human health narrative criterion developed for drinking water, at the point of intake, or at some other point established by the Director at a distance not to exceed one-half mile upstream of the intake. The permittee may establish the location of the nearest downstream public water supply intake using the Bureau of Public Health list of public water supplies, and by performing a survey of downstream water users. B. The WVMA Supports the Use of the Harmonic Mean Flow for Calculating Permit Limits for Carcinogens The WVMA agrees that the appropriate design flow for calculating permit limits for carcinogens is the harmonic mean flow. This is the flow regime used by neighboring states and is endorsed in EPA’s Technical Support Document for Water Quality-based Toxics Control, EPA/505/2-90-001 (March 1991) (the TSD). Human health criteria for protection of water supplies is developed assuming many years of drinking water drawn from affected streams, and it is appropriate to assume that average, not low flow, conditions apply over the course of many years. 6 Page 356 of 465 C. The Human Health Design Flow Basis for Noncarcinogens Should Be Modified to Include Measures Based on Human Health Exposure The Proposed Rule includes the use of 30Q5 flow to calculate permit limits for human health criteria that are noncarcinogens. The WVMA supports the use of the 30Q5 flow for noncarcinogens; however, a design flow value that is representative of the human health exposure time period should also be allowed. The TSD states that “if the effects from certain noncarcinogens are manifested after a lifetime of exposure, then a harmonic mean flow may be appropriate.” TSD 89. By allowing different flow measures based on the human health exposure time period to calculate permit limits, the DEP would enhance the ability of manufacturers and citizens alike to use West Virginia’s water resources. The WVMA proposes that the DEP delete the period at the end of the last sentence of §8.2.b, as proposed for amendment by the DEP, and add the following: “, unless it is established that the harmonic mean flow would be a more appropriate design flow.” D. Spatial Limitations on Mixing Zones Established for Human Health Should be Removed. The Proposed Rule still includes limits on the spatial area allowed for mixing zones, regardless of whether the mixing zone is established for the protection of aquatic or human life. For instance, “the mixing zone shall not exceed one-third (1/3) of the width of the receiving stream, and in no case shall the mixing zone exceed one-half (1/2) of the cross-sectional area of the receiving stream.” 47 C.S.R. 2-5.2.e. Moreover, the Proposed Rule prohibits mixing zones that “extend downstream at any time a distance of more than five times the width of the receiving watercourse at the point of discharge” or that “overlap one another”. 47 C.S.R. 25.2.h.2 and 5.2.h.5. Although such rules may make sense for mixing zones established for the protection of aquatic life, there is no need to extend spatial limitations to mixing zones 7 Page 357 of 465 established for the protection of human health because water quality at the water intake is still protected. The DEP has sufficient authority to waive the restrictions in §§ 5.2.e and 5.2.h.2 but not the prohibition against overlapping mixing zones in §5.2.h.5. All three waivers are appropriate for human health, because the receptor is the public water intake, not an instream organism. As long as the mixing zone does not overlap the half mile area above an intake, as provided in §5.2.h.6, human health will be protected regardless of how large the mixing zone is upstream. There are other protections as well that are not waivable, such as “mixing zones for human health criteria shall be sized to prevent significant human health risks.” 47 C.S.R. § 2.5.2.c. This language preserves the DEP’s ability to restrict the size of mixing zones in situations where there are adverse human health effects, while allowing relief where there is no demonstrable risk posed by a larger mixing zone. The WVMA proposes that the DEP add §5.2.h.5 to the list of sections in §5.2.j that can be waived by the DEP. E. Bacteria Standard Should Include Wet Weather Exceedances WVMA supports the use of E. coli as an indicator for bacteriological pathogens. However, the DEP should consider including an allowance for wet weather exceedances where the permittee can demonstrate that bacteria exceed the criteria because of runoff, not industrial or municipal operations. This would allow manufacturers to focus their energies on mediating the discharge of bacteriological pathogens actually related to their industrial activities. 8 Page 358 of 465 F. The Aluminum Testing Method Should Be Re-Evaluated or the Limits Should Be Revised Recently, two West Virginia University professors published a study calling into question the reliability of EPA’s recommended method for analyzing aluminum. Y. Thomas He and Paul F. Ziemkiewicz, Bias in Determining Aluminum Concentrations: Comparison of Digestion Methods and Implications on AI Management, 159 Chemosphere 570 (2016). The investigators found that EPA’s method 200.7 significantly over-estimates the amount of dissolved aluminum in the water supply, especially in high pH conditions with clay particulate. Id. Because only dissolved aluminum harms aquatic life, there is no environmental reason to include aluminum attached to particulate in the discharge calculations. In light of this report, the DEP should consider alternative means of analyzing aluminum discharges and consider whether an alternative method should be developed for translating dissolved aluminum criteria into total aluminum limits in NPDES permits. In order to maintain water quality standards that properly balance the environmental and economic development interests at play, alternative techniques and protocols are available. For instance, ASTM International recommends using a process involving atomic absorption in order to determine the amount of aluminum in water. ASTM D857-12, Standard Test Method for Aluminum in Water, ASTM International. Whatever the correct analytical method or approach, West Virginia’s businesses should not be forced to comply with an unnecessarily stringent aluminum standard. G. Net Limits Under the state’s NPDES permit regulations, 47 CSR. 10, a procedure for setting net limits is allowed for certain technology-based limits. There is no reason that netting should not 9 Page 359 of 465 also be allowed for water quality-based permit limits, such as where a permittee causes a reduction in the pollutants in a certain waterbody. For instance, where a permittee could establish that high levels of iron are present in the intake water, and lower levels of iron are present when that water is discharged into the same waterbody, the discharge should be allowed even if it would exceed the water quality criteria for iron. In that situation, the net effect of the permittee’s actions is less iron in the water. The permittee should not be punished by criteria requiring further removal of a substance that it has already helped to reduce from its ambient concentration. The WVMA recognizes that netting may not be appropriate for all pollutants, that it would not be available where the net effect of the discharge was an increase in loading, and that allowing netting might require additional monitoring of intakes. However, we believe permittees should be given the option to use netting in setting permit limits. This could be done by adding the following language as Section 8.6: “Water quality-based permit limits may be developed for pollutants on a net basis upon demonstrating to the Secretary that the pollutant is discharged in lower concentrations than the concentration of the same pollutant in the permittee’s intake, or upon such other demonstration approved by the Secretary.” H. New Criteria The proposed rule incorporates aquatic life criteria for five organic chemicals: acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. We are concerned that there are not laboratories certified in West Virginia to analyze for these substances. The WVMA is requesting a list of certified laboratories that are approved to perform the test methods for each organic chemical, and we seek confirmation that the method detection limit is achievable, and will allow 10 Page 360 of 465 dischargers to establish compliance with the proposed aquatic life criteria. We would also like to know whether the DEP has data demonstrating that that the methods have passed data validation reviews consistently without qualifiers or rejection, and are requesting any information the DEP has on proficiency test samples for these chemicals. We are also interested in any information the DEP has on the additional costs for this testing and for approval certifications by a lab. F. Conclusion WVMA appreciates the opportunity to provide these comments to WVDEP and requests that they be given careful consideration by the DEP. Respectfully Submitted, Rebecca McPhail, President West Virginia Manufacturers Association August 9, 2016 11 Page 361 of 465 August 9, 2016 Laura Cooper Water Quality Standards Program WV Department of Environmental Protection 601 57th St., S.E. Charleston, WV 25304 Submitted electronically to Laura.k.cooper@wv.gov RE: Requirements Governing Water Quality Standards Dear Ms. Cooper, These comments elaborate on our previous triennial review comments as well as respond to some of the information presented in the proposed rule governing Water Quality Standards. They are being submitted on behalf of West Virginia Rivers Coalition and the organizations and individuals signed below. Category A West Virginia is a headwaters state. Eleven other states depend on WV’s waters for their drinking water after it leaves our state, therefore all waters upon leaving the state should meet Category A use for human consumption as a good faith effort to our neighboring states. We strongly support the current, long-standing, status of Category A designation for all waters within West Virginia. The current definition of Category A says the state must protect future use. A new state law requires utilities to develop source water protection plans which study the feasibility of secondary intakes or backup sources. Over the next several years, water utilities will be identifying a backup source of water in the event of an emergency. This law makes it especially crucial to preserve the future use of drinking water in sources where the flow makes it a feasible source. Making sure the State’s rivers and streams are adequately protected for future drinking water use is prudent management. We applaud the state’s policy to protect all of our water supplies with adequate flows for future drinking water use. Triennial Review Comments August 9, 2016 1 Page 362 of 465 Category A is the most stringent standard for 60 parameters that are known or suspected carcinogens. Removing Category A Use Designation from any portion of a state water would allow higher concentrations of known or suspected carcinogens into the waters of the state. If the state allows a use removal though an NPDES permit, more carcinogens will be discharged into a waterbody that has insufficient flow for dilution. Those carcinogens will then flow downstream into a waterbody that has sufficient flow for drinking water use which would adversely impact the health and safety of our current and future populations and users downstream. We cannot allow more carcinogens into our water simply because at that particular location the water is not used for drinking, because the water is still used for drinking downstream of that point. Pursuant to Clean Water Act (CWA) regulations, “[i]n designating uses of a water body and the appropriate criteria for those uses, the State shall take into consideration the water quality standards of downstream waters and shall ensure that its water quality standards provide for the attainment and maintenance of the water quality standards of downstream waters.” 40 C.F.R. § 131.10(b). Because the Category A Use Designation protects the population from known carcinogens, the statewide designation must be preserved in the interest of public health. The new rule allows WVDEP to limit the application of Category A use designation through the National Pollutant Discharge Elimination System (NPDES) process based on insufficient flow or hydrologic modification. Allowing a use removal of Category A through the NDPES permitting process may circumvent the process outlined in the Clean Water Act. Pursuant to 40 C.F.R. § 131.10, “[t]he classification of waters of the State must take into consideration the use and value for public water supplies, protection and propagation of fish, shellfish and wildlife, recreation in and on the water, agricultural, industrial, and other purposes, including navigation.” If a state wishes to remove a designated use it must submit to EPA, “documentation justifying how their consideration of the use and value of water for those uses. . . appropriately supports the State’s action.” Additionally, a revision to water quality standards (as well as the issuance of a NPDES permit) must comply with the minimum requirements of the CWA’s antidegradation policy. In the case of high quality waters—those exceeding the fishable/swimmable goals of the CWA—the state must make certain required findings before the lowering of water quality is allowed. Specifically, “the State shall find, after an analysis of alternatives, that such a lowering is necessary to accommodate important economic or social development in the area in which the waters are located. The analysis of alternatives shall evaluate a range of practicable alternatives that would prevent or lessen the degradation associated with the proposed activity.” 40 C.F.R. § 131.12(a)(2)(ii). which requires a use attainability analysis and approval of the legislature and EPA. The provisions for Category A use removal should be improved to Triennial Review Comments August 9, 2016 2 Page 363 of 465 include evaluations of water quality, not simply the physical properties of the stream at issue. We object to this proposed method to remove the use of Category A. Under Section 6.3a Insufficient Flow, the rule states that the Secretary shall consider whether the insufficient flow may be compensated for by the effluent discharge to meet the use. We question whether an effluent dominated flow should be considered as potential source water. If there is insufficient flow to meet Category A, then there may not be sufficient flow to provide dilution for the effluent discharge. A case in point is the 1988 incident in the City of Buckhannon in Upshur County when the Buckhannon River (source of the public water supply) was quite low and the effluent from the large surface mine upstream at Tenmile constituted a major source of water in the river. Water treatment systems were overwhelmed and complaints of nasty water and cream curdling in coffee were plentiful. More expensive water treatment measures have since been added to the basic operation of the water plant and cost to local users increased. As stated previously, water utilities are currently identifying secondary or backup water sources. Section 6.3.a.3 states that the Secretary shall consider whether the water could serve as a backup water supply. The criteria should also be included in Section 6.6 where it states that the Secretary shall ensure that the water is not currently used as a water supply and shall require the applicant to demonstrate that the water supply has no potential for future use as a backup water source. Under Section 6.6c the rule states that the applicant shall make a determination of the connection between the wells or springs and the surface water in question. Groundwater under the direct influence of surface water is a common occurrence in West Virginia. The applicant must be required to hire a qualified individual to make a GWUDI determination based on criteria such as physical parameters in wells and surface waters in nearby streams and monitoring bacteria (bacti test) to determine which groundwater sources are affected by surface water sources. Critical Design Flow for Human Health Criteria Although the Harmonic Mean Flow is the critical design flow recommended by EPA, there are certain instances where the Harmonic Mean Flow is not a good indicator of flow and should be recognized as such by DEP. The Harmonic Mean Flow is not an appropriate flow measurement when there are seasonably variable effluent discharge rates and hold and release treatment systems. At effluent dominated sites, the effluent load and downstream flow are not independent of each other. Instead of harmonic mean flow, a modeling technique should be used which calculates the average daily concentration of criteria pollutants over time. Triennial Review Comments August 9, 2016 3 Page 364 of 465 Harmonic Mean is not designed for low flows because it assumes the flows are log-normally distributed. It’s less protective of exposure to carcinogens during low flows, allowing more pollution when there is not enough of a dilution factor. Knowledge of magnitude and frequency of low flows for streams is imperative for calculating waste load allocations (WLA), recreational contact safety, and protecting aquatic life. Low-flow statistics are needed for water quality regulatory activities to be used as thresholds when setting allowable pollutant loads to meet water quality standards. Reliable estimates of stream flow must be calculated for low-flow periods when determining TMDLs or WLA for NPDES permits. Since stream gages are not located within every stream in the state, accurate methods are needed for estimating harmonic mean flows and low flow frequencies at un-gaged streams. Therefore, we request WVDEP work with USGS to conduct a statewide study to develop regression equations for low-flow frequency statistics and estimation equations for harmonic mean flow statistics to update and improve the accuracy of the estimates. We request that WVDEP use best-fit equations for calculating harmonic mean flow. Simple equations based on drainage area only have larger prediction errors than the best-fit equations. Best-fit equations quantify the basin characteristics using GIS. Simple equations that do not account for basin characteristics exhibit geographic biases for most stream flow statistics. We urge WVDEP to use a regionalization approach to calculate flow rates based on hydrologic characteristics, landform regions, and soil regions to provide the best estimates of flow. We encourage WVDEP to work with USGS to develop weighted-least-squares regression equations for each region to estimate harmonic mean flow statistics. Caution should be used when applying equations for basins with characteristics near applicable limits of equations and basins within karst topography, which underlies much of the eastern part of the state. We refer WVDEP to the comments submitted by Affiliated Construction Trades Foundation in 2003 when the change to Harmonic Mean was first proposed. Those comments prepared by Carpenter Environmental Associates gave recommendations on the areas of study to determine the impacts of the proposed changes. Specifically, they recommended a determination of the need for revisions to critical design flow for human health carcinogens, a determination of health impacts as a result of the proposed change to Harmonic Mean Flow, and a determination of the economic impact of revising the critical design flow. The use of Harmonic Mean for critical design should not be adopted until the impacts of the revision is fully investigated. It is vital to the future health of West Virginians that prior to adopting this change, WVDEP must determine the amount of increased carcinogens to be discharged into WV waters as a result of changing from 7Q10 to Harmonic Mean. Triennial Review Comments August 9, 2016 4 Page 365 of 465 Biotic Ligand Model for Copper We support the revision to use the Biotic Ligand Model (BLM) for Copper to develop sitespecific numeric criteria. The BLM represents the best current and available science. Application of this model is the best way to ensure that resulting criteria will be protective of aquatic life designated uses. The BLM provides better accounting for the effects of individual parameters and can be used to develop site-specific criteria for copper by characterizing the bioavailability of metals at a site. The BLM can significantly improve predictions of acute toxicity of certain metals across an expanded range of water chemistry parameters. Replacing Fecal Coliform with E. Coli as Bacterial Indicator Other states that have converted from fecal coliform to E. coli have a transition period where both the old and the new bacterial criteria run concurrently until the department has adequately collected E. coli data on the streams. This transition process should be explicitly stated in the water quality standard. All streams listed as impaired based on the existing fecal coliform criterion should remain on the 303(d) list, unless new E. coli data are collected that specifically contradict the existing impairment. Additionally, we have serious concern over the daily maximum criterion included in the previously proposed revision. Understanding that when WVDEP collects fecal coliform data, it rarely does so more than once a month during routine testing done under the watershed management framework, we are concerned that the proposed daily value for E. coli “not to exceed a concentration level of 1074 cfu/100 ml” is likely to become the default criterion - this would result in criteria less stringent than our existing criteria. This daily maximum criterion should be dropped and the proposed 410 cfu/100 ml should be interpreted the same as the prior fecal coliform criterion i.e., that one sample > than 410 cfu/100 ml is an exceedance of the water quality standard as it would be equal to 10% exceedance even if 10 samples were taken in that month and 9 of those samples were less than 410 cfu/100ml. The added daily value provision to the proposed was confusing and could be interpreted and applied as a weakening of the current bacteria standard and should be removed. Aquatic Life Criteria We commend WVDEP on taking EPA’s recommendations and adopting standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin and encourage WVDEP to adopt the other 91 standards for organic chemicals that EPA recommends. Triennial Review Comments August 9, 2016 5 Page 366 of 465 Thank you for taking these comments into consideration. Sincerely, Angie Rosser & Autumn Bryson West Virginia Rivers Coalition Cindy Ellis & Cindy Rank West Virginia Highlands Conservancy Gary Zuckett West Virginia Citizens Action Group Julie Archer West Virginia Surface Owners’ Rights Organization Janet Keating Ohio Valley Environmental Coalition Larry V. Thomas Friends of Beautiful Pendleton County Brent Walls Upper Potomac Riverkeeper Nancy Novak & Helen Gibbins League of Women Voters of West Virginia Leslee McCarty Greenbrier River Watershed Association Cathy Kunkel Advocates for a Safe Water System Chad Cordell Kanawha Forest Coalition Triennial Review Comments August 9, 2016 6 Page 367 of 465 Arthur W. Dodds, Jr. Laurel Mountain Preservation Association Cierra Pennington West Virginia Environmental Council Triennial Review Comments August 9, 2016 7 Smith, Chris B From: Sent: To: Subject: Page 368 of 465 Matthew Thiele Tuesday, August 09, 2016 3:09 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, I am writing to ask you to please make sure that West Virginia's water quality standards continue to protect public health and recreational safety. Please do not let industry degrade the public's water quality and quality of life. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. Matthew Thiele thielem@hotmail.com 1 Page 369 of 465 905 Walnut Street Glenville, WV, West Virginia 26351 Smith, Chris B From: Sent: To: Subject: Page 370 of 465 Mike Manypenny Tuesday, August 09, 2016 2:33 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, It is much easier and more cost effective to mitigate pollution before it happens rather than try to clean it up later on the taxpayers dime. We cant have this pollute for profit mentality too continue. We need to responsible and hold all industry accountable for its actions. Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. 1 Page 371 of 465 Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. Mike Manypenny manypenny51@gmail.com Rt 3 Box 202 Grafton, West Virginia 26354 2 Smith, Chris B From: Sent: To: Subject: Page 372 of 465 Matt Wyatt Tuesday, August 09, 2016 2:14 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 373 of 465 Thank you for the opportunity to comment. Matt Wyatt matt.wyatt1980@gmail.com 4320 wells st Weirton, West Virginia 26062 2 Smith, Chris B From: Sent: To: Cc: Subject: Page 374 of 465 Brian Dorsey Tuesday, August 09, 2016 3:27 PM DEP Comments Chris Hale WV Waters - Today's Meeting and Beyond! Laura Cooper  Water Quality Standards  DWWM  WV Department of Environmental Protection  601 57th St. S.E.  Charleston, WV 25304    Dear Ms. Cooper:    Please know that I stand in solidarity today and every day with the "Friends of Water" organization in regard to  protecting WV's precious rivers, lakes and streams!      WE RESPECTFULLY URGE the WV‐DEP:    1)  to include a 300 uS/cm standard for electrical conductivity in West Virginia Water Quality Standards.  Since  conductivity is easily measured, numerous scientific studies and EPA have concluded that electrical conductivity greater  than 300 uS/cm is harmful to aquatic life.     2)  to protect “Category A Drinking Water”.  Streams that can serve as sources of public drinking water are designated  “Category A”.  WV‐DEP proposes to allow pollution discharge permits to remove this Category A designation from a  stream.  PLEASE delete sections 6.3 through 6.9 of the proposed rule.  This proposed language is entirely focused on  allowing more pollution.  Water Quality Standards should be about protecting drinking water and other water uses!    3) to reject proposed changes to the “Critical Design Flow”.  WV‐DEP proposes to change this calculation to allow higher  rates of carcinogens in water.  While EPA has supported this in some cases, it is not appropriate during drought or low  flow periods. PLEASE establish procedures to reduce the amount of carcinogens during low flow periods.    4) to increase monitoring of E. coli and fecal coliform bacterial contamination.  PLEASE increase the required sampling  frequency to assure safety for swimming and boating.    5)  to adopt as proposed EPA’s recommended standards for aquatic life criteria for five organic chemicals:  acrolein,  carbaryl, diazinon, nonylphenol, and tributyltin.  PLEASE recognize that these compounds are toxic and West Virginia  needs these water quality standards.      The safety and health of every West Virginian and each visiting tourist is in your hands today. PLEASE stand up for WV's  waters to keep us safe for decades to come!     Thank you.    Brian Dorsey  bdorsey@aol.com  1 87 Melbourne LN Page 375 Of 465 Pool, WV 26684 Sent from my iPhone Smith, Chris B From: Sent: To: Subject: Page 376 of 465 Kelly Shreve Tuesday, August 09, 2016 3:04 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 377 of 465 Thank you for the opportunity to comment. Kelly Shreve kshreve50@gmail.com 725 Rowan Rd. Gap Mills, Rio de Janeiro 24841 2 Smith, Chris B From: Sent: To: Subject: Page 378 of 465 Amanda Stoner Tuesday, August 09, 2016 2:27 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 379 of 465 Thank you for the opportunity to comment. Amanda Stoner amstoner@mix.wvu.edu 107 Uvilla Road Harpers Ferry, WV, West Virginia 25425 2 Smith, Chris B From: Sent: To: Subject: Page 380 of 465 Kelli Hall Tuesday, August 09, 2016 2:12 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 381 of 465 Thank you for the opportunity to comment. Kelli Hall cheesegenius@yahoo.com 223 Gallagher St Huntington, West Virginia 25705 2 Smith, Chris B From: Sent: To: Subject: Page 382 of 465 Charlotte Fremaux Tuesday, August 09, 2016 3:19 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, We need more protective standards for water quality, not compromises. I support protecting all waters as current or future drinking water sources and oppose any rollback of this longstanding policy; I reject changes to the “critical design flow” that would allow more carcinogens into our water; and I support increased statewide monitoring for bacteria in our waters. Our watersheds, streams and rivers are under great stress. This is no time to roll back protections. Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. 1 Page 383 of 465 Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. Charlotte Fremaux cmfremaux@gmail.com 175 Fern Drive HARPERS FERRY, West Virginia 25425 2 Smith, Chris B From: Sent: To: Subject: Page 384 of 465 Barrie Kaufman Tuesday, August 09, 2016 2:59 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 385 of 465 Thank you for the opportunity to comment. Barrie Kaufman artistbarrie@ail.com 410 Sheridan circle Charleston wva, West Virginia 25314 2 Smith, Chris B From: Sent: To: Subject: Page 386 of 465 Christopher Pennington Tuesday, August 09, 2016 2:23 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 387 of 465 Thank you for the opportunity to comment. Christopher Pennington penningtonc24@gmail.com 7 Pine Knoll Apt 4 Oak Hill, West Virginia 25901 2 Smith, Chris B From: Sent: To: Subject: Page 388 of 465 Suzanne Hornsby Tuesday, August 09, 2016 2:00 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 389 of 465 Thank you for the opportunity to comment. Suzanne Hornsby tealturtle86@hotmail.com 814 Station Camp Rd Leroy, West Virginia 25252 2 Page 390 of 465 Smith, Chris B From: Sent: To: Subject: Paul Howe III Tuesday, August 09, 2016 2:48 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. We need to address the over fluoridation of our environment. This toxic waste product is dripped into our potable water as a deterrent for dental carries. However, the CDC claims less than a 30% reduction from fluoridation. Fluoride is toxic to the environment and cost prohibitive to remove for sanitation plants and consumers who want chemical free water. Thank you for the opportunity to comment. Paul Howe III paulhowe3@gmail.com 315 So Chestnut St Clarksburg, West Virginia 26301 1 Smith, Chris B From: Sent: To: Subject: Page 391 of 465 Marz Attar Tuesday, August 09, 2016 2:20 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 392 of 465 Thank you for the opportunity to comment. Marz Attar marzattar@gmail.com 125 White Stick Rd Beckley, West Virginia 25801 2 Smith, Chris B From: Sent: To: Subject: Page 393 of 465 Clarence Mizell Tuesday, August 09, 2016 3:28 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 394 of 465 Thank you for the opportunity to comment. Clarence Mizell c_mizell@frontier.com 202 Bostick Ave Beckley, West Virginia 25801 2 Page 395 of 465 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY a REGION 1% a 1650 Arch Street W4, ango? Philadelphia, 19103-2029 Ms. Laura K. Cooper, Assistant Director W3 5 9 ME Water Quality Standards Division of Water and Waste Management West Virginia Department of Environmental Protection 601 57*? s: SE Charleston, WV 25304 Dear Ms. Cooper: The US. Environmental Protection Agency (EPA), Region has reviewed the proposed amendments to West Virginia?s ?Requirements Governing Water Quality Standards? (Title-Series, 47? 02). This proposal, which was announced for public review and comment in the West Virginia Register on June 17', 2016, constitutes West Virginia?s current triennial review of its water quality standards, as required by the Clean Water Act (CWA or ?the Act?) Section 303(c)(1). The purpose of this letter is to provide comments on the proposal. Please note that the comments and recommendations contained in this letter are strictly for the West Virginia Department of Environmental Protection?s (WVDEP) consideration and do not constitute approval or disapproval decisions under CWA 303(c) and 40 CPR ?131.21. Neither are these comments a determination by the EPA Administrator under CWA Section 303(c)(4)(B) and 40 CPR ?131.22(b) that revised or new standards are necessary to meet the requirements of the Act. This letter includes comments on the proposed revisions, as well as additional revisioos EPA would like West Virginia to consider adopting: Category A Designated Use Removal Process for Insuf?cient Flow and Hydrologic Modi?cations WVDEP is proposing to establish a process by which the Category A Public Water Supply use designation can be removed through the NPDES permitting process. The process could be used when it is determined that a surface water cannot support the Public Water Supply use based on either insuf?cient ?ow or hydrologic modi?cation. The process in and of itself is not a water quality standard subject to EPA review under CWA Section 303(c); any removal of Category A uses (either individual or categorical) would still need to be adopted pursuant to state law, and submitted to EPA for review under CWA Section 303(c). EPA is offering comments on the process mindful that EPA would ultimately need to review any removal of Category A uses adopted pursuant to this process. Printed on 100% recyclerb?recycfabfe paper with H3096 post-consmner?ber andpraeess drier-inc free. Customer Service Hartline: 1-300-438-24174' Page 3&6 of 465 Because Category A use is not a use speci?ed in CWA 101(a)(2) (Le. protection and propagation of ?sh, shell?sh, and wildlife and recreation in and on the water), West Virginia is not required to conduct a use attainability analysis prior to removing the Category A use. However, in accordance with 40 CFR West Virginia must submit documentation justifying how their consideration of the ?use and value? of water for the Public Water Supply use appropriately supports the State?s action to remove the use. 80 FR 51026. When determining the use and value of a stream, States must consider protection and existing uses of the water. WVDEP does appropriately note the consideration of protection in 412-63, but should also reiterate in this process that existing uses, as de?ned 47?2-16 cannot be removed. In other words, a water that has been used as a public water supply on or after November 28, 1975 cannot be removed, regardless of the ?ow or hydrologic modi?cations. When considering the use and value of a surface water, EPA recommends states also take into account a suite of facts, including but not limited to: I Relevant descriptive information identi?cation of the use that is under consideration for removal, location of the water body/waterbody segment, overview of land use patterns, summary of available water quality data andfor stream surveys, physical information, information from public comments andfor public meetings, anecdotal information, etc. - Attainability information the 13 .10(g) factors) if applicable - Value andz?or bene?ts (including environmental, social, cultural, andfor economic valuer?bene?ts) associated with either retaining or removing the use, - Impacts of the use removal on other designated uses, including designated and existing uses. In addition to the information above, should provide EPA and the public with documentation that: the drinking water use is not an existing use; the nearby population uses an alternative drinking water supply; and projected population trends suggest that the current supply is suf?cient to accommodate future growth. States should make this documentation available to the public prior to any public hearing, and submit it to EPA with the WQS revision. The proposed process does indicate that any determination under subsection 6.3 that the Category A use does not apply shall be subject to approval by EPA. WVDEP should clarify that the use removal is not effective until approved by EPA under CWA 303(c). Finally, changes to use designations need to be legally binding located in state regulations). WVDEP needs to provide a legal explanation of how these use removals executed through the NPDES permit process are legally binding, not only for the permittee but for the water segment as a whole, and after the permit expires. 47-2-6.l WVDEP is proposing to modify this provision of the regulation to read that a designated use which is not an existing use may be removed if the permit applicant (emphasis added) can demonstrate that attaining the designated use is not feasible. EPA believes WVDEP is proposing this modi?cation to support the addition of the proposed Category A Use Removal process. EPA believes this modi?cation may have the consequence of limiting use removals to NPDES permit holders. Please support if that is intention. Otherwise, EPA suggests that the proposed language revert back to the current language. Page 337 of 465 Critical Design Flow for Human Health Criteria West Virginia is proposing to rede?ne critical design flow for human health criteria by using harmonic mean flow for carcinogens, and 30Q5 flow for noncarcinogens. In the preamble to the Federal Register notice announcing the availability of 2000 Methodology fer Deriving Ambient Water Quality Criteria for the Protection of Human Health, EPA recommends the harmonic mean flow as the design How to be used to implement both carcinogen and noncarcinogen human health criteria. 65 FR 66450. Harmonic mean flow should be used to implement human health Criteria because, by and large, human health criteria are designed to protect an individual over a lifetime of exposure. By this recommendation, EPA is attempting to match the longest stream ?ow averaging period (using harmonic mean) with the criterion which is protective over a human lifetime. EPA recommends that WDEP modify this revision to reflect harmonic mean flow as the critical design flow for both carcinogens and noncarcinogens. However, West Virginia has the prerogative to retain flows that will result in a more stringent application of the State?s human health criteria. Establishment of Site?Speci?c Criteria In 47-2-8.5.a, WVDEP is proposing to establish a process by which site?speci?c criteria can be established through the NPDES permitting process using a Water Effect Ratio study pursuant to interim Guidance on the Determination and Use of Water-E?ect Ratios for Metals February I994) or a site-specific numeric criterion for copper derived using the the Biotic Ligand Model (BLM) as described in Aquatic Li?r Ambient Freshwater Quality Criteria Copper 07-00 I, February 2007). As with the Category A removal process, this provision for establishing certain site?speci?c criteria is not a water quality standard subject to EPA review under CWA Section 303(c). As written, addition of this process does not change the fact that in order for site-specific criteria to be effective for CWA purposes, they are required to be approved by EPA under its CWA 303(c) authority. EPA is willing to work with WVDEP if it would like to explore development of a performance-based process that articulates how to derive site-dependent criteria that are protective of designated uses. Adoption of E. coli for Protection of Waters Designated for Water Contact Recreation EPA is pleased that West Virginia is proposing to adopt E. coli criteria that for the most part appears to be consistent with recommendations found in ?Recreational Water Quality Criteria? (EPA-820- F-12-058). In order to be wholly consistent with EPA recommendations, EPA recommends WVDEP revise ?nor shall E. coli concentration exceed 410 cfui 100 ml in more than ten percent of all samples taken during the same month" to ?nor shall E. coli concentration exceed 410 c?1i100 ml more than 10% of the time in the same month.? As written it appears that West Virginia?s criteria would be based on number of samples collected vs. the intended duration and frequency that no value can exceed 410 cfui100 ml more than 10% of the time regardless of the number of samples. Also, WVDEP should remove the provision ?based on no less than three samples per month.? Data suf?ciency sample size) is not a reviewable element ofa water quality standards submission as determined by 40 CFR but it could be considered in review as it relates to the criteria?s scientific defensibility and protectiveness of the use. Data suf?ciency is more appropriately addressed in the development of the State?s assessment methodologies. Page 398 of 465 Adoption of Water Quality Criteria for Certain Organic Chemicals WVDEP is proposing to adopt EPA 304(a) recommendations for the following criteria for the protection of aquatic life: chronic criteria for acrolein, carbaryl, diazinon and acute chronic criteria for and tributyltin (TBT). Although acute criteria recommendations are available for acrolein (Ambient Aquatic Life Water Quaiity Criteria for Acroiein, July 1, 2009), carbaryl (Aquatic Life Ambient Water Quality Criteria for Cat-beryl, April 2012) and diazinon (Aquatic Life Ambient Water Quality Criteria for Diazinon, December 2005), WVDEP has not proposed adoption of acute criteria, as those numbers are the same as the chronic recommendations. EPA notes that although the acute and chronic magnitudes for these criteria are the same, the frequency and duration differ, and therefore would make a difference in the implementation of these criteria for CWA purposes such as the development of water quality-based ef?uent limits in NPDES permits, and assessment of water quality. EPA recommends that WVDEP modify this revision to include the acute criteria for acrolein, carbaryl and diazinon. New or Updated Section 304(a) Criteria Recommendations In August 2015, EPA revised the WQS regulations at 40 CFR Part 131. As part of that revision, states are now required to provide an explanation if not adopting new or revised criteria for parameters for which EPA has published new or updated CWA Section 304(a) criteria recommendations. 40 CF This change was made to foster meaningful and transparent involvement of the public and intergovernmental coordination with local, state, and federal entities in light of recent science provided by EPA through its criteria recommendations. EPA will not approve or disapprove this explanation. For West Virginia?s triennial review, the state will need to provide explanations where new or revised criteria are not adopted for parameters where EPA has published new or updated CWA Section 304(a) criteria recommendations since May 30, 2000. These would include: I Acute criteria for acrolein, carbaryl and diazinon (if WVDEP chooses not to include the acute criteria numbers per comment above). I Ammonia criteria for the protection aquatic life, including freshwater mussels listed as endangered or threatened under the Endangered Species Act (ESA). (Aquatic Life Ambient Water Quaiity Criteria for Ammonia Freshwater, April 2013) I Selenium criterion for the protection of aquatic life (Aquatic Life Ambient Water Quaiity Criteria for Selenium Freshwater, June 2016). West Virginia has adopted fish tissue elements consistent with EPA recommendations, but needs to review the water column elements of selenium criterion. I Updated ambient water quality criteria for the protection of human health, 80 36986. I Application, statewide, of the Aquatic Life Ambient Freshwater Quaiity Criteria Copper (EPA- 322-R-02-001, February 2007). I Cadmium criteria for the protection of aquatic life (Aquatic Life Ambient Water Quality Criteria for Cadmium, EPA-820-R-16-002, March 2016). WVDEP can link to additional information on all of these parameters through Water Quality Criteria website at: Page 339 of 465 Additional EPA Recommendations for Revisions in this Triennial Review of West Virginia?s Water Quality Standards Regulation I 47-2-7.2.d.l6 establish site speci?c selenium criterion for Connors Run and Little Scary Creek of 62 ugll. EPA has recently published new selenium criteria for the protection of aquatic life (EPA 322-R-16-006). That document includes guidance for developing modi?ed selenium criteria to re?ect site?speci?c conditions where the scienti?c evidence indicates that different values will be protective of aquatic life and provide for the attainment of designated uses. WVDEP should review the site-speci?c criteria for Connors Run and Little Scary Creek in light of new guidance, and determine if they are scienti?cally defensible and protective of designated uses as required by 40 CF ?131.1 l. In this triennial review, WVDEP is proposing to specify the critical flow for the application of criteria for the protection of human health. WVDEP should also consider specifying the eriteria flow for the application of the aquatic life Criteria. According to the EPA document Technical Support Document for Water Quality-based Toxics Control March 1991), TQIO is recommended for the application of chronic criteria, and 1Q10 for the application of acute. EPA will be providing a copy of this package to the US. Fish and Wildlife Service (USFWS) so that USFWS may identify any issues with this action. We will notify WVDEP of any issues raised. This coerdination with the USFWS will help to ful?ll obligations under BSA, and facilitate CWA Section 303(c) action once this rulemaking is ?nalized and submitted to EPA for review. Thank you for this opportunity to provide comments on West Virginia?s triennial review of its water quality standards regulation. EPA would be happy to assist the State as necessary to complete this triennial review. If you have any questions concerning this letter, please contact me at (215)814-5717, or have your staff contact Denise Hakowski at (215)814-5726. Sincerely, 2 Evelyn . MacKnight, Associa irector Of?ce of Standards, Assessment Water Protection Division Page 400 of 465 Water Quality Standards Program WV Department of Environmental Protection 601 57th St., S.E. Charleston, WV 25304 Public Comments for Proposed Water Quality Standards Think of Our Children Section 1) If the Proposed Changes to Water Quality apply in any way to the Oil and Natural Gas Waste Stream, WVDEP Must Collaborate with West Virginia Bureau for Public Health WVBPH in Order to Change Water Quality Standards as per the West Virginia Radiological Health Rule. Both the WVDEP and WVBPH have regulatory authority over the oil and natural gas waste stream. This should force both agencies to collaborate in the case that the proposed water quality standards apply to the Oil and Gas waste stream in any way. The WVBPH has the duty to ensure the safety of drinking source waters and public utility drinking water. It is essential that the WVDEP seeks the approval of the proposed water quality standards by WVBPH. Section 2) The State of West Virginia Cannot Afford the Monetary Cost of Removing Class A Protections, Increasing Concentration of Any Chemicals, or Reducing Protections of Any Streams. Appropriate Public Health Monitoring to Facilitate Proposed Changes in Water Quality Standards Does Not Exist: Many county health departments do not have environmental health professionals on staff, but rather sanitarians. This leaves West Virginia county health boards very little options in the case that a perceived public health issue arises. With all environmental health issues being sent to the centralized environmental health professionals at WVBPH, we have reason to believe that each issue does not get the attention it deserves under current WVBPH staffing infrastructure. We have concluded that the following health monitoring infrastructure would have to exist, at the very least. Before permitting of any locale by WVDEP:     Hiring of full-time environmental health professionals at every county health department Each industry be mandated to disclose any compound or chemical to be managed at or released from every locality. West Virginia Bureau for Public Health review of all findings surrounding said compounds or chemicals. Widespread preliminary public health surveying of residents with surveys that include health effects and symptoms found during discovery of public health findings surrounding said chemicals or compounds After permitting of any locale by WVDEP:  Frequent public health surveying of residents in the county where any WVDEP permitted localities exist and at any locality that would be affected by any increased concentrations of chemicals or compounds in their waters. This surveying should be mandated to include potential symptoms of exposure to said chemicals and compounds.  Access to medical professionals qualifiedPage to treat 401 illnessof caused 465by exposure to said chemicals and compounds should be guaranteed to any and all residents and people spending time in areas potentially impacted by removal of protections and increased concentration of chemicals. Current Water Quality monitoring of Drinking Source Waters and Public Utility water are Grossly Insufficient. Sufficient Monitoring is Not Economical for the State of West Virginia and Public Utility Providers under Current Water Quality Standards. The This Impact Would be Worsened by Lifting Stream Protections and Allowing Increased Concentrations of Compounds into Waterways.      Endocrine Disrupting Chemicals (EDCs) can be harmful to people and wildlife if ingested in concentrations less than 10 parts per trillion. There is currently not any requirements to monitor drinking source water and residential public utility service in the appropriate concentration. Appropriate monitoring for EDCs would be incredibly expensive for public water utility service providers and WVBPH. If anyone notices problems with the drinking water from their tap, there are currently no water testing resources that are accessible to public water utility users. Testing is too expensive for most people. People with well water may be impacted by lifting protections on streams. Water sampling resources for private wells are scarce and unaffordable for most. When the water flowing out of taps at Fayetteville Elementary School was discolored and odorous, the local health board only had resources to test the drinking water for lead and fecal coliform. The only other activity that is acceptable for county health departments to do is to forward complaints and requests to WVBPH. Fayetteville Elementary School has yet to see sufficient water testing to this day, and the problems with water quality in the school have yet to cease. Fayette County hosts legacy mining activity, current mining activity, and commercial disposal of oil and gas waste. Even though all of these industrial practices produce EDCs, no appropriate tests for EDC content in water have been performed. WVDEP must be ready to provide comprehensive water quality monitoring for streams in the case that stream protections are removed and increased concentrations of carcinogens and EDC’s are allowed in order to ensure the health and safety of the public and protect the environment. Comments Prepared and Submitted 8/9/2016 by: Brandon Richardson Jerry Allen Sandra Keeney Redden Brittany Huerta Danielle Crouch Matthew D.W. Webb Kristine Crouch-Gilkey Autumn Crouch Mary E.R. Webb Thomas Rhule Jean Evansmore Christopher Pennington Alice Beecher Patrick M. Webb Justin Coen Gary Crouch Danielle R. Lewis Natasha Green Amy Crouch Lisa H. Henry Josh Jones Page 402 of 465 West Virginia Coal Association PO Box 3923, Charleston, WV 25339 - (304) 342-4153 - Fax 342-7651 August 9, 2016 Ms. Laura Cooper West Virginia Department of Environmental Protection Division of Water 8: Waste Management 601 57th Street Charleston, WV 25304 Via Electronic Mail: Re: A337 Triennial Review of State Water Qualitv Standards Dear Ms. Cooper: Pursuant to the public notice published by the West Virginia Department of Environmental Protection (WV DEP), the West Virginia Coal Association (WVCA) offers the following comments regarding the 2017 Triennial Review of state water quality standards. WVCA appreciates the opportunity to provide comments to WV DEP regarding the proposed revisions to the state?s water quality standards program. The West Virginia Coal Association (WVCA) is a nonprofit state coal trade association representing the interests of the West Virginia coal industry on policy and regulation issues before various state and federal agencies that regulate coal extraction, processing, transportation and consumption. general members account for 98 percent of the Mountain State?s underground and surface coal production. WVCA also Comments of the West Virginia 0an Association: Triennial Review of Water Quaiity Standards August 9. 2016 Page 403 of 465 represents associate members that supply an array of services to the mining industry in West Virginia. primary goal is to enhance the viability of the West Virginia coal industry by supporting efficient and environmentally responsible coal removal and processing through reasonable, equitable and achievable state and federal policy and regulation. WVCA is the largest state coal trade association in the nation. Overall, WV DEP is to be commended for the pronounced improvements to the water quality standards rulemaking process since assuming that duty from the Environmental Quality Board in 2005. Recent revisions preposed by WV DEP to have updated specific water quality criteria that were maintained without adequate scientific justification. These changes will improve the relevancy of the state?s water quality standard and NPDES programs and will remove unnecessary compliance complications. However, the statewide application of the Category public drinking water supply use designation maintained by WV DEP continues to be an unsubstantiated interpretation of West Virginia?s water quality standards that has created substantial regulatory confusion and imposed significant compliance costs (with no benefit) on the coal industry. Previous comment filings by WVCA regarding the state?s water quality standards program and individual water quality criteria have detailed the history and technical particulars of the contrived interpretation of Category A by the E08 and WV DEP. These Comments of the West Virginia Coal Association: Trienniai Review of Water Quality Standards August 9, 2016 Page 404 of 465 previous comments were filed with WV DEP on September 30, 2015, and we ask the agency to consider the sections and supporting attachments related to Category A as comments on the current agencyeproposed revisions. The past comments are particularly instructive regarding the substantial confusion surrounding the application of Category A criteria. The references to the administrative history of the state?s manganese water quality criteria provide a workable example of an efficient and common sense approach to address the legislative mandate regarding Category A. Additionally, WVCA endorses the comments filed by the West Virginia Manufacturers Association on the proposed revisions. On March 12, 2015 the West Virginia Legislature passed House Bill (HB) 2283. Signed by the Governor on March 31, 2015, the bill requires WV DEP in the 2017 triennial review cycle to examine its application of Category A to all waters statewide: The legislative rule filed in the State Register on August 1, 2014, authorized under the authority of section four, article eleven, chapter twenty-two of this code, relating to the Department of Environmental Protection (requirements governing water quality standards, 47 CSR 2), is authorized. Provided; that the Secretary of the Department of Environmental Protection shall consider, for the 2017 triennial review, potential alternative applications for the Category A drinking water use designation to the waters of the state, taking into consideration stream flow, depth, and distance to a public water intake (emphasis added).1 Enrolled Committee Substitute for House 33111 2283, pg. 4, March 2015. Text Comments of the West Virginia Coai Association: Triennial Review oi Water Quality Standards August 9, 2016 Page 405 of 465 Unfortunately, WV DEP has shunned the common sense approach to protecting actual public water supplies presented by the manganese criteria and proposed a meandering, regulatory labyrinth that will require individual applications and subsequent approval by the agency, the West Virginia Legislature and the federal Environmental Protection Agency (EPA). The current proposal is also disappointing in that WV DEP has ignored the Legislature?s instruction to consider ?distance to a public water intake? in favor of preserving the EQB-devised and WV DEP-perpetuated bureaucratic fantasy that all waters of the state are public drinking water supplies, despite previous instructions from the Legislature that was not the case. The tortured interpretation of statewide Category A application by the EQB and now WV DEP caused substantial compliance issues related to manganese and resulted in adverse environmental impacts from the application of chemical agents to maintain compliance with a misplaced standard. After many years of languishing under the rulemaking procedures and in the federal review process, a revised state standard for manganese was finally approved in 2005 (referred to as the ?Mn-5?Mile Rule?). West Virginia?s approved manganese Category A water quality standard, (which was only necessary because of the misplaced application of the drinking water use to all state waters), applies five miles above public and private drinking water intakes: Comments of the West Virginia Coat Association: Triennial Review of Water Quality Standards August 9, 2016 Page 406 of 465 manganese human health criterion shall only apply within the five- mile zone immediately upstream above a known public or private supply used for human consumption.?2 WV DEP supported the revision to the manganese criterion, and EPA acknowledged in its approval letter that the application of drinking water criteria at the point of intake is reasonable, protective, and consistent with water quality standards programs implemented in other states: change in the water quality standard should not have an impact on the water withdrawn for drinking, the drinking water treatment processes and the cost treating water for drinking, All water withdrawn for drinking by private and public intakes that was covered under the designated use and thus protected by the manganese criterion prior to the MN S?mile rule continues to be subject to the applicable lmg/L manganese criterion. Therefore, application of the MN S?mile rule continues to protect the public water supply The application of a criterion for the protection of public water supply at the intake point is consistent with approval in other states. EPA has approved applications of human health criteria at the intake or withdrawal points in other states as approval of the S?mile rule and its supportingjustification presents a very practical question to WV DEP with regard to application of drinking water criteria to all state waters: If application of the Category A use designation at the point of intake is protective of ?all water withdrawn for drinking? and if "application of the Mn 5?mile rule continues to protect the public water supply? as EPA observed in its approval 2 47 CSR 2.6.2.d. 3 Letter dated June 29, 2005 from EPA Region to the EQB approving West Virginia?s manganese standard. 4 . Ibui Comments of the West Virginia Coal Association: Triennial Review of Water Quality Standards August 9, 2016 Page 407 of 465 documents, then why would a similar approach not be protective and warranted for other parameters? WV DEP has largely ignored this comment and the simple solution it offers to end the Category A controversy, choosing instead to hide behind the fabricated justification for statewide application. WVCA was hopeful that HB 2283 would finally lead the agency lead the agency to consideration of a similar, common sense approach for other parameters. Respectfully Submitted, Jason D. Bostic Vice-President Comments of the West Virginia Coat Association: Triennial Review of Water Quality Standards August 9, 2016 Smith, Chris B From: Sent: To: Subject: Page 408 of 465 MaryAnn McGowan Wednesday, August 10, 2016 8:48 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 409 of 465 Thank you for the opportunity to comment. MaryAnn McGowan riversnlakes23@gmail.com PO Box 332 Hico, West Virginia 25854 2 Smith, Chris B From: Sent: To: Subject: Page 410 of 465 Gina Schrader Tuesday, August 09, 2016 11:02 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 411 of 465 Thank you for the opportunity to comment. Gina Schrader ginaschrader@yahoo.com 825 Byus Drive charleston, WV, West Virginia 25311 2 Smith, Chris B From: Sent: To: Subject: Page 412 of 465 Jessica Chasengnou Tuesday, August 09, 2016 7:31 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 413 of 465 Thank you for the opportunity to comment. Jessica Chasengnou jessica.m.cha@gmail.com 743 Whispering Oaks Ln Saint Albans, West Virginia 25177 2 Page 414 of 465 Smith, Chris B From: Sent: To: Subject: Becky Park Tuesday, August 09, 2016 5:38 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, There is nothing as important as clean water in our streams, as it effects so many aspects of the web of life and humanity. Please do not revmove and requirements for Class A stream purity, and proceed carefully to conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. I do not agree with the proposed Harmonic Mean flow estimate. We are facing uncertain climate situations which may create droughts in our state. The proposed flow estimate procedure would not be adequate and would increase the possibility of carcinogens in our waters. Let's be smart and stringent and return West Virginia to the pristine conditions that will draw people to our state. Thank you for the opportunity to comment. Becky Park rebeccamasonpark@gmail.com 943 Mathews Ave Charleston, West Virginia 25302 1 Page 415 of 465 Smith, Chris B From: Sent: To: Subject: Mary Lee Wednesday, August 10, 2016 7:35 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, LET'S STOP MINCING WORDS. STOP STROKING THE INDUSTRIES THAT PAD YOUR PERSONAL POCKETS!!!!! Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. Mary Lee maryfleas@aol.com 1 Page 416 of 465 228 FRANCIS MINE RD FAIRMONT, West Virginia 26554 Smith, Chris B From: Sent: To: Subject: Page 417 of 465 Joy Woodrum Tuesday, August 09, 2016 10:44 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 418 of 465 Thank you for the opportunity to comment. Joy Woodrum wvwoodjoy@aol.com 107 Hayes Ave. Charleston, West Virginia 25314 2 Smith, Chris B From: Sent: To: Subject: Page 419 of 465 Sarah Corley Tuesday, August 09, 2016 7:12 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 420 of 465 Thank you for the opportunity to comment. Sarah Corley corley.daugherty@gmail.com 3423 Union Rd Philippi, West Virginia 26416 2 Smith, Chris B From: Sent: To: Subject: Page 421 of 465 JERRY PAYNE Tuesday, August 09, 2016 5:20 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 422 of 465 Thank you for the opportunity to comment. JERRY PAYNE jacabay@yahoo.com 69 FAIRPLAIN MOBILE HOME PARK RIPLEY, West Virginia 25271 2 Smith, Chris B From: Sent: To: Subject: Page 423 of 465 Tracy King Wednesday, August 10, 2016 6:32 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 424 of 465 Thank you for the opportunity to comment. Tracy King showdator@yahoo.com 105 HAYMARKET DR BECKLEY, West Virginia 25801 2 Smith, Chris B From: Sent: To: Subject: Page 425 of 465 Sabrina Shrader Tuesday, August 09, 2016 2:16 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 426 of 465 Thank you for the opportunity to comment. Sabrina Shrader sabrinashrader@ymail.com 609 Hale Avenue Princeton , West Virginia 24740 2 Smith, Chris B From: Sent: To: Subject: Page 427 of 465 Marilyn Howells Tuesday, August 09, 2016 6:37 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 428 of 465 Thank you for the opportunity to comment. Marilyn Howells mhowe9876@gmail.com 5364 Newcomb Ck. Rd. Huntington, WV, West Virginia 25704 2 Smith, Chris B From: Sent: To: Subject: Page 429 of 465 Beverly Martin Tuesday, August 09, 2016 4:57 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 430 of 465 Thank you for the opportunity to comment. Beverly Martin bayoubev@hotmail.com 250 Lakeview Dr Morgantown , West Virginia 26508 2 Page 431 of 465 Smith, Chris B From: Sent: To: Subject: Annette Yurkovich Brichford Wednesday, August 10, 2016 1:09 AM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Growing up in McDowell County and later working there from 2005-2011, I saw firsthand the effects of allowing sewage and mine run-off to enter rivers and streams. Today residents fish those streams but release their catches because they dare not eat the trout or other species from those polluted waters. In Mercer County, where I now live, algae blooms that may be caused by fertilizer runoff make our drinking water foul in taste and odor every summer. My mother's water source, the Green Valley-Glenwood PSD, sent a letter to its customers last winter detailing higher than permitted levels of certain cancer-causing substances. To put it plainly, even our treated water is not safe enough. Please keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate 1 Page 432 of 465 is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. Annette Yurkovich Brichford ays40@frontiernet.net 195 Butternut Dr Princeton, West Virginia 24740 2 Smith, Chris B From: Sent: To: Subject: Page 433 of 465 William Skaggs Tuesday, August 09, 2016 8:40 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 434 of 465 Thank you for the opportunity to comment. William Skaggs weskaggs.wes@gmail.com 656 Martin Road Grafton, West Virginia 26354 2 Page 435 of 465 Smith, Chris B From: Sent: To: Subject: Brian Washington Tuesday, August 09, 2016 6:12 PM DEP Comments WV DEP water standards hearing Dear Ms. Cooper, In addition to the pre-prepared statement below, I'll include a brief statement on why I am passionate on the subject of water quality in WV. I recently made the decision to remain employed in the mountain state, despite the potential for higher earnings, more progressive community programs and infrastructure opportunities in neighboring states within our nation. A key component in my choice to stay is the recreational opportunities that are abundant in this state, and the natural beauty of the bounty of rivers here. I work in home health, and work with many of the retired coal miners, loggers, and native population of WV, and many will tell stories of how their profession has "killed" many streams and rivers in mountain state, and they lament the loss of once abundant natural life. Resource industry is a vital part of WV economy currently, but it is finite, and can exist without such long term impact on the fragile resources we have that effect the health and quality of life of so many west virginians. Please help Protect west virginia's health, and one of the few sources of population influx in a state that desperately needs a reason for skilled workers to stay. Respectfully, Brian Washington, DPT. Laura Cooper Water Quality Standards DWWM WV Department of Environmental Protection 601 57th St. S.E. Charleston, WV 25304 Dear Ms. Cooper: Please know that I stand in solidarity today and every day with the "Friends of Water" organization in regard to protecting WV's precious rivers, lakes and streams! WE RESPECTFULLY URGE the WV-DEP: 1) to include a 300 uS/cm standard for electrical conductivity in West Virginia Water Quality Standards. Since conductivity is easily measured, numerous scientific studies and EPA have concluded that electrical conductivity greater than 300 uS/cm is harmful to aquatic life. 2) to protect “Category A Drinking Water”. Streams that can serve as sources of public drinking water are designated “Category A”. WV-DEP proposes to allow pollution discharge permits to remove this Category A designation from a stream. PLEASE delete sections 6.3 through 6.9 of the proposed rule. This proposed language is entirely focused on allowing more pollution. Water Quality Standards should be about protecting drinking water and other water uses! 3) to reject proposed changes to the “Critical Design Flow”. WV-DEP proposes to change this calculation to allow higher rates of carcinogens in water. While EPA has supported this in some cases, it is not appropriate during drought or low flow periods. PLEASE establish procedures to reduce the amount of carcinogens during low flow periods. 1 Pagebacterial 436 ofcontamination. 465 4) to increase monitoring of E. coli and fecal coliform PLEASE increase the required sampling frequency to assure safety for swimming and boating. 5) to adopt as proposed EPA’s recommended standards for aquatic life criteria for five organic chemicals: acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. PLEASE recognize that these compounds are toxic and West Virginia needs these water quality standards. The safety and health of every West Virginian and each visiting tourist is in your hands today. PLEASE stand up for WV's waters to keep us safe for decades to come! Thank you. -Brian D. Washington DPT, Marshall University M.S. in Adapted Physical Activity Fayetteville, WV (304) 654-0612 Washinbd@gmail.com 2 Smith, Chris B From: Sent: To: Subject: Page 437 of 465 Doris Irwin Tuesday, August 09, 2016 4:54 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. 1 Page 438 of 465 Doris Irwin dorisirwinmobile@yahoo.com 771 Turtle Ridge Rd Princeton , West Virginia 24739 2 Smith, Chris B From: Sent: To: Subject: Page 439 of 465 Theresa Dennison Tuesday, August 09, 2016 11:10 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water standards should only be raised! Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 440 of 465 Thank you for the opportunity to comment. Theresa Dennison theresagarrett@hotmail.com Po box 271 Stanaford, West Virginia 25927 2 Page 441 of 465 Smith, Chris B From: Sent: To: Subject: Daven Marrin Tuesday, August 09, 2016 7:38 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Have you people lost your minds or your souls? Our rivers are toxic enough already! All the mess with Dow and C-8 and the toxic coal industry chemicals and other industrial waste and spillage? You want to lower water standards? How about NO! People in WV are crapped on enough by a greedy government and heartless companies. Why not think of the citizen's health and not letting fat cats run extra dirty toxic businesses? Daven Marrin lvxfvxo@yahoo.com 730 South St. Morgantown, West Virginia 26505 1 Smith, Chris B From: Sent: To: Subject: Page 442 of 465 Gabriele Koenig Tuesday, August 09, 2016 5:41 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, I will become a WVa resident in 2017. One of the reasons I selected WVa is the natural beauty. One of the reasons I selected the parcel of land I bought is because the quality of spring water is superb. Why, why, why would any official seriously consider any legislature that could lessen standards? When will improvement and health win over industry? Will you be the champion of this fragile "blue marble" or of industry that can find better ways and not be lazy about waste and contamination? Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. 1 Page 443 of 465 Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. Thank you for the opportunity to comment. Gabriele Koenig gabyderek@gmail.com 1515 Farlow Avenue Crofotn, Maryland 21114 2 Smith, Chris B From: Sent: To: Subject: Page 444 of 465 ben morgan Tuesday, August 09, 2016 4:07 PM DEP Comments Water Quality Standards Laura Cooper, Dear Ms. Cooper, Water Quality Standards need to protect and maintain water quality for safe use and enjoyment. Some of the changes proposed during the current triennial review raise concerns because they will allow more pollution in our water. Keep our water quality standards protective of public health and recreational safety: Remove the provision to allow Category A use change through a NPDES permit that is contrary to the Clean Water Act's process for the removal of a designated use. The provisions for Category A use removal should include thorough evaluations of water quality, not simply the physical properties of the stream at issue to assure the protection of public health and drinking water users downstream. Conduct a statewide study in collaboration with USGS to determine the best estimates for flow which take into account low flow conditions. The proposed Harmonic Mean flow estimate is not appropriate in all circumstances, especially during drought conditions. Develop a procedure that measures both Fecal Coliform and E. Coli as the bacterial indicators until enough data is collected on E. Coli to ensure the water is safe for recreation. Increase sampling frequency to measure the monthly average values for more priority watersheds. Adopt as proposed EPA’s recommended standards for aquatic life criteria for 5 organic chemicals; acrolein, carbaryl, diazinon, nonylphenol, and tributyltin. 1 Page 445 of 465 Thank you for the opportunity to comment. ben morgan morgan8n@yahoo.com 103 fayette ave fayetteville, West Virginia 25840 2 Page 446 of 465 West Virginia Council of Churches WV DEP Triennial Review Testimony August 9, 2016 Good evening. My name is Rev. Jeff Allen and I am the executive director of the West Virginia Council of Churches. I am native West Virginian and I grew up in Glen Dale, a small town situated between the Ohio River and the hill. At the base of the hill is a small stream, inhabited largely by snails, minnows, and crawdads. To the best of my knowledge, it is not used as a source of drinking water, but I can tell you, that growing up there as a kid, I played in that stream many days for many years during the summer and even some during the winter. I think that there must many small streams like this across West Virginia, with many snails and minnows and many small children who have played and will continue to play in those streams in the future. I am greatly appreciative that all streams in West Virginia are protected through Category A regulations and I, personally, would strongly oppose the weakening of those standards. The West Virginia Council of Churches, ?rst organized in 1880 and made up of fourteen member denominations, supports policies that ensure water quality. Page 447 of 465 The Council notes that with increased oil and gas exploration come additional challenges in protecting our state?s water resources and encourages the Department of Environmental Protection to strengthen rules that safeguard water quality and quantity. The Council encourages the state and its agencies to adopt and enforce the federal Clean Water Act standards and the Council supports the highest level of protection possible for our ?nest streams. Lastly, the Council urges that narrative standards for mercury, selenium, and other toxic metals should not be compromised, as these elements pose many dangers to human health, and especially the health of our children. The West Virginia Council of Churches hopes that the DEP will keep Category A regulations as they are in order to protect all steams in West Virginia. Thank you! Page 448 of 465 August 7, 2016 Comment on WV DEP Proposed Modi?cations to 47 CSR 2 W05 Rules: My name is Philip C. Price. I have a inAnaly?cal Chemistry, with over 40 years' experience in industrial chemistry, trace analyses, spill/release incident investigations, and Superfund Site remediation. I have comments on two areas of the proposed changes: Drinking Water Use Designation DEP proposes to remove these designations of potential ?Jture source water use. One prediction we can all agree with is that WV will see more change in the future: new industries, shifting populations, economic challenges, and new environmental events (algae blooms, spill events, ?oods). Last summer's sudden algae bloom events clearly demonstrated the use?ilness of an alternate clean emergency water source for Huntington. Degrading our currently-available alternate water supplies increases ?iture risks to Public Health. This change seems driven mainly by WV manufacturers. Are there any data to demonstrate speci?c WV economic bene?ts ?if we could only degrade the water quality of this speci?c stream?? Implement EPA-recommended Harmonic mean flow DEP proposes increasing the amount of permissible carcinogens (and other pollutants) in WV waters by changing the ?ow/dilution calculation factors. Some of the increases would be more than 10-fold, based on stream ?ow data. However, there is a lack of data on carcinogen and polutant identities, current concentrations, and proposed future concentrations. ?Without this data, the rule would be changed, but without any information as to its impact on Public Health or speci?c aquatic toxicity mcrease. Hallo i r} aha %J{v;g LG ?t ?rm Co-u?ider' m, came/n; Pg? in cud] ?b3 momr/Jm 650.31.] ?5 ?de. Mo?s?i ?:3:le TD/O?Qahhi? Mimi's bdrm/(? 'thsf' (ixde 79 ?Ht, Cum/r)" ?61/2/ 0% Vote?hm will dgb?imen?alaa/ ka/a mailbag o?P ?ap; DJ who [Vi-6 13 CA When MW do;on av? 030w) d? 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Fred Peggy Sarah Sarah Amyr Debbm tamara Tursia Scott Joanna Stephanie Lisa Jared Mitchell Apel Ferguson Wack Perry Bennett Parsons Ricketts Aros Graham Baxter Belcher Murray Haltom Hoskinson Rose Price Vaughan Scherer Fuller Madison Bisbee Mesa Los Angeles San Clemente Westbrook Spring Hill Berea Frankfort Hyattsville Salem Liverpool Jamesville Elyria Cleveland Columbus Xenia kette ring Dayton Cleveland Philadelphia New Castle Marianna Highland Page 451 of 465 state zip comment AL 35757 AZ 85603 We all live .Headwater streams are where pure water is made. Clean water is our Az 35201 most valuable resource! CA 90026 The destruction of miles upon miles of streams in West Virginia due to the practice of Mountaintop Removal (or ?bombing' as it should be by the coal industry is, in and of itself a travesty of humanity and justice. The destruction of this vital part of local ecosystems, as well as the drinking water of hundreds of thousands of people is something that cannot be overlooked. The state and federal government must step up and hold the coal industry reSponsible for the clean-up of CA 92672 its mess. CT 6498 FL 34610 KY 40404 KY 40601 MD 20782 Clean Water is for everyone NJ 8079 NY 13908 NY 13078 OH 44035 OH 44105 OH 43235 OH 45385 This is an outrage! Water is life period. You take OH 45429 clean water away what do you have left? OH 45403 You can't keep people from their God giving OH 44109 Rights PA 19144 PA 16101 PA 15345 UT 84003 Patricia Ann Karen Janet Smith Malone Saunders Bernhard Wood bridge sugar grove Brattleboro Richmond VA VA Page 452 of 465 What affects WV often affects VA waters too, water is going to be "liquid gold" if we don't take 22192 care to treat it as our number 1 commodity. People's health should be more important than 24375 corporate profit! 5301 5477 Page 453 of 465 Dear Laura Cooper, Assistant Director, Water Quality Standards, 47CSR2 Water standards rule comments, and Randy Huffman, Cabinet Secretary, WVDEP, We are pleased to present you with this petition af?rming this statement: "Reject proposed weakening of WV water quality standard 47CSR2. WVDEP should: reject the ?harmonic ?ow? estimate that would allow higher levels of carcinogenic discharges, and instead work with USGS to develop an estimate that accounts for low ?ow conditions; remove the change that allows a pollution permit to remove Category A drinking water designation from streams; develop a procedure that measures both Fecal Coliform and E. Coli as bacteria] indicators for water recreation safety; adopt recommended standards for aquatic life criteria; and adopt a 300 uS/cm conductivity standard to protect aquatic life from mine runoff and other threats." Attached is a list of individuals who have added their names to this petition, as well as additional comments written by the petition signers themselves. Sincerely, Vernon Haltorn Move_On.org Page 454 of 465 Peter Schumacher Pennsboro, WV 26415 Aug 9, 2016 Patti Goldstein New Martinsville, wv 26155 Aug 9, 2016 Aryn Princeton, WV 24739 Aug 9, 2016 William Hawkins Weston, WV 26452 Aug 9, 2016 You are our protection. Please take care of this most vital responsibility to insure safe, clean waters for West Virginia Jeanne Wahl Lewisburg, WV 24901 Aug 9, 2016 Hannah Lashmeet, WV 24733 Aug 9, 2016 Protect our water. Several years ago I heard a WVDEP rep say it was OK to increase mercury limits because West Virginians don't eat much fish anyway. I would love to if there were not limits on how many you can eat before being poisoned. Department of Environmental Protection - that says it all. Do your job! Jane Friedmann Alum Bridge, WV 26321 Aug 9, 2016 Teresa Parcell Elkview, WV 25071 Aug 9, 2016 Pam Harris Stonewood, WV 26301 Aug 9, 2016 MoveOn.org 2 Page 455 of 465 Dear ms. Cooper and mr. Huffman, Why don?t you both put your mouth where your money is? Your job is to protect MY water source, yet frack waste and other vile pollutants have been found in the creek along my property. I've been using Wolf Creek water since I was a young kid, and now my kids ,are being exposed to all the toxins YOU were supposed to protect us from. Thanks. Anyway, since I'm sure you are doing a fabulous job at what you do best, I'd like to issue you a "one glass at day" challenge. My friends from Headwaters Defense and I will bring you both a tall glass of Wolf Creek water every single day for a year. Feel free to contact me to make arrangements, and we will get it set up for you. Since you guys are ones that regulate our water quality, I'm sure you?ll have no qualms with having a taste of what my family lives with on a daily basis. Sincerely, Sandra Keeney Redden sandra keeney redden fayetteville, WV 25840 Aug 9, 2016 kenneth 1 king ethel, WV 25076 Aug 9, 2016 Al Justice War, WV 24892 Aug 9, 2016 Danielle Maness Charleston, WV 25314 Aug 9, 2016 Rita Winser Fayetteville, WV 25840 Aug 9, 2016 Amy Fabbri Petersburg, WV 26847 Aug 9, 2016 Mary Sullivan Charleston, WV 25314 Aug 9, 2016 Zoe monis St albans, WV 25177 Aug 9, 2016 Cindy Welch West Union, WV 26456 Aug 9, 2016 MoveOn.org 3 Page 456 of 465 We already have too many chemicals and bacteria in our water. How can this even be considered after our water crisis two years ago? No wonder we?re losing population. Stop chasing the extractive industries and diversify our economy. Regina Hendrix Charles Town, WV 25414 Aug 9, 2016 Patrick McIntire Center Point, WV 26339 Aug 9, 2016 Patricia Schumacher Pennsboro, WV 26415 Aug 9, 2016 West Virginia politicians are doing everything they can to accommodate extractive industry, under the mistaken notion that this will make the state appealing and bring in jobs. Corporations may love getting cheap access to West Virginia's resources, but who would send valued employees into a state where water and air are so polluted they are unhealthful? Rather than weakening environmental protections we should be strengthening them, imposing stronger protections than EPE or any other function of the Federal government. Thomas Bouldin Talcott, WV 24910 Aug 9, 2016 The precious clean water resources of WV are under attack. Our drinking water resources need additional protection and more rigid enforcement of the regulations. Do not weaken, but work to strengthen these protections. Alfred Tuttle Middlebourne, WV 26149 Aug 9, 2016 We have major water quality issues in WV please don?t allow this to decrease the quality even further. wendy johnston Athens, WV 24712 Aug 9, 2016 MoveOn.org 4 Page 457 of 465 Please do not worl to lessen water quality standards. I moved my family back to West Virginia and the disregard for its citizens is glarineg obvious in comparison to my experiences'living elsewhere. A comment like this might bare little weight from a technical perspective and to not consider its gravity is the very disregard to which I refer. But, for context, such emotionally charged responses are indeed part of the numbers game. You're draining the state of its current and future potential with the lessening of water quality standards, who will stay, and who will come? These are the questions you should ask when considering yet another industry-favoring policy change that will push people out the door in order to escape and raise their children in a place where the government can actually be trusted in its role to protect its people. Adam Webster Morgantown, WV 26501 Aug 9, 2016 LYN BORDO GREENWOOD, WV 26415 Aug 9, 2016 Linda Harrington Wallace, WV 26448 Aug 9, 2016 Anthony Ervolina West UNion, WV 26456 Aug 9, 2016 Sharron Hendrick-Jackson Pullman, WV 26421 Aug 9, 2016 Rozanna Bracken Charleston, WV 25314 Aug 9, 2016 Cherie Buzzard Naoma, WV 25140 Aug 9, 2016 Margaret Spencer Crab Orchard, WV 25827 Aug 9, 2016 Elizabeth Dennis Littleton, WV 27581 Aug 9, 2016 Wayne Rebich Beaver, WV 25813 Aug 9, 2016 MoveOn.org Page 458 of 465 Elizabeth Scott Win?eld, WV 25213 Aug 9, 2016 Katherine Cockerham Copen, WV 26615 Aug 9, 2016 Michelle Walker Saint Albans, WV 25177 Aug 9, 2016 Tina Del Prete West Union, WV 2645 6?8285 Aug 9, 2016 Ahmed Sakkal Charleston, WV 25301 Aug 9, 2016 Clint Henry Beckley, WV 25801 Aug 9, 2016 Justin Raines Walkersville, WV 26447 Aug 9, 2016 Keep our waterways clean! We already are drinking enough pollution! Michelle mallamo fairmont, WV 26554 Aug 9, 2016 Wendy. L. Knadler Martinsburg, WV 25403 Aug 9, 2016 Lori Rose Dunbar, WV 25064 Aug 9, 2016 Yes please the water crisis we underwent two years ago was simply awful and our water has not been the same ever since! Joshua Carpenter Cross Lanes, WV 25313 Aug 9, 2016 MoveOn.org Page 459 of 465 This is the of rivers, not pro?t. Jason Reott Fayetteville, WV 25840 Aug 9, 2016 b0 Webb Naoma, WV 25140 Aug 9, 2016 LAURA Salem, WV 26426 Aug 9,2016 Kevin Campbell Adrian, WV 26210 Aug 9, 2016 Terry Schnell Morgantown, WV 26508 Aug 9, 2016 Mckey Elliott Craigsville, WV 26205 Aug 9, 2016 K. Giltin Charleston, WV 25330 Aug 9, 2016 Joan hansen Beckley, WV 25801 Aug 9, 2016 We need to find better ways to protect our water! Jessica Blalock Charleston, WV 25304 Aug 9, 2016 WVDEP has a poor track record using "estimates". The water quality standards should not change until a true study has been completed. Daile Boulis Charleston, WV 25314 Aug 9, 2016 MoveOn.org 7 Page 460 of 465 Anne Axel Huntington, WV 25701 Aug 9, 2016 Nanette Nelson Racine, WV 25165 Aug 9, 2016 Paul Nelson Racine, WV 25165 Aug 9, 2016 George Mace Craigsville, WV 26205 Aug 9, 2016 What's in this for us? This change would be a real step backward. It's a betrayal of the many to bene?t the few. Jennifer Lee Parkersburg, WV 26101 Aug 8, 20 1 6 DeWayne Ewing Beckley, WV 25 801 Aug 8, 2016 Yeah. I agree that more corporations should make more insane amounts of money off of polluting our natural resources, while we are left with nothint when their toxic resources spill over into our water because they dont actually care sbout standards. And i think its great that no one is ever held accountable. We should not be allowing more pillutants, and more streams desecrated. We should ve cutting back and attempting to fix the streams that are damaged. Michael A. Moore Charleston, WV 25304 Aug 8, 2016 Sara Wilts Bruceton Mills, WV 26525 Aug 8, 2016 Judy Hunter Huntington, WV 25701 Aug 8, 2016 Robin cathell Rowlesburg, WV 26425 Aug 8, 2016 MoveOncrg 8 Page 461 of 465 Richard Charles Town, WV 25414-0694 Aug 8, 2016 Just Our waterways are a precious DO NO Carol Shef?eld Buckhannon, WV 26201 Aug 8, 2016 We are led by ignorant hicks. Shame on you. Jeff Wilson Morgantown, WV 26505 Aug 8, 2016 Nicholas Cheremisinoff Charles Town, WV 25414 Aug 8, 2016 Tatyana Cheremisinoff Charles Town, WV 25414 Aug 8, 2016 JChase Charleston, WV 25314 Aug 8, 2016 Nancy Whalen Shepherdstown, WV 25443 Aug 8, 2016 Legislators seem to have little regard for our state's water ways. We need higher standards to protect our drinking water. Additionally the of Rivers National Monument would illustrate a commitment to honoring the value of water to everyone. Michael Condon Hillshoro, WV 24946 Aug 8, 2016 Air and water are our most precious and life giving pesuxs of nature. Without them we would die. Therefore, keep them both pure as we can have them. Richard D. Reece Romney, WV 26757-6589 Aug 8, 2016 MoveOn.org Page 462 of 465 Carole Williams Fairmont, WV 26554 Aug 8, 2016 Petra Miller Lost Creek, WV 263 85 Aug 8, 2016 James Norton Fairmont, WV 26554 Aug 8, 2016 Lucas Garrett Camden, WV 26338 Aug 8, 2016 Karen Anderson Elkins, WV 26241 Aug 8, 2016 Donna Showalter Morgantown, WV 26508 Aug 8, 2016 William Scott Rose South Charleston, WV 25303 Aug 8, 2016 Diane Wellman Huntington, WV 25701 Aug 8, 2016 Robert Oliver Scott depot, WV 25560 Aug 8, 2016 Vivian Stockman Huntington, WV 25773 Aug 8, 2016 Robin Blakeman Huntington, WV 25705 Aug 8, 2016 Taylor Boggess Huntington, WV 25701 Aug 8, 2016 MoveOn.org 10 Page 463 of 465 Charles Bonner Grafton, WV 26354 Aug 8, 2016 Jessica Woods Huntington, WV 25701 Aug 8, 2016 June Kemp Bluefield, WV 24701 Aug 8, 2016 Daniel Chiotos Harpers Ferry, WV 25425 Aug 8, 2016 Jamie Shultz Morgantown, WV 26508 Aug 8, 2016 Caresta Click Skelton, WV 25919 Aug 8, 2016 Maureen Farrell Beverly, WV 26253 Aug 8, 2016 Joshua Carpenter New Haven, WV 25265 Aug 8, 2016 save our streams PLEASE Steve Can?ey Naoma, WV 25140 Aug 8, 2016 Angela Lucas Amett, WV 25007 Aug 8, 2016 jesse 6 price arnett, WV 25007 Aug 8, 2016 jody price arnett, WV 25007 MoveOn.org 11 Page 464 of 465 Aug 8, 2016 Junior Walk Whitesville, WV 25209 Aug 7, 2016 Whitney Eskew Huntington, WV 25701 Aug 7, 2016 Michael Morrison Barboursville, WV 25504 Aug 7, 2016 Please, our kids and grandkids do matter! Debbie Jarrell rock creek, WV 25140 Aug 7, 2016 Vernon Haltom aoma, WV 25140 Aug 7, 2016 MoveOn.org 12 Page 465 of 465 Comments of West Virginia Chapter of Sierra Club Water Standards Hearing Aug. 9, 2016 Please accept these comments on behalf of the approximately 2000 members of Sierra Club in West Virginia. We appreciate the opportunity to comment on 47-CSR-2 during this triennial Review of Water Quality Standards. While some aspects of proposed rule are appropriate, key parts need to be strengthened to protect water quality in West Virginiaurge to include a 300 uS/cm standard for electrical conductivity in West Virginia Water Qualitl Standards. Electrical conductivity is abroad measure of the level of chemical ions such as sulfate, bicarbonate, calcium, chlorides, and many other dissolved solids. Sources include mining operations, gas well development, road salts, and other activities. waterhigh. in conductivity is acutely toxic to many species of aquaticlife. Since conductivity is easily measured, numerous scienti?c studies and EPA have concluded that electrical conductivity greater than 300 uS/cm is harmful to aquatic life. Protect ?Category A Drin_king Water?. Streams that can serve as sources of public drinking water are designated ?Category Current standards apply this designation to almost all waters in West Virginia, thereby protecting those streams for current and future water supplies. WV-DEP proposed rule would allow pollution discharge permits to remove this Category A designation from a stream. We urge DEP to delete sections 6.3 through 6.9 of the props rule. This proposed language is entirely focused on allowing more pollution. . Water Quality Standards should be about protecting drinking water and other water uses! Reject proposed changes to the ?Critical Design Flow?. The Critical Design Flow is used to estimate the water?s ?ow rate in receiving streams. proposal to change this calculation to use Harmonic Mean Flow will allow higher rates of carcinogens in water. While EPA has supported this in some cases, it is not appropriate during drought or low ?ow periods because that will allow higher concentrations of carcinogens. We demand that WV- DEP establish procedures to reduce the amount of carcinogens during low ?ow periods, and reconsider whether adding carcinogens in ANY amount is good for West Virginia.. Re uire increased monitorin of E. coli and fecal coliform bacterial contamination. Water with high levels of fecal coliform bacteria is unsafe for recreation. WV-DEP should increase the required sampling frequency to assure safety for swimming and boating. Ado as ro osed recommended standards for a uatic life criteria for ?ve organic chemicals; acrolein, carbaryl, diazinon, and tributyltin. These compounds are toxic and West Virginia needs these water quality standards. .- ank you for helping to protect West Virginia?s water. Jim Kotcon, Conservation Chair, WV Sierra Club P. O. Box 4142, Morgantown, WV 26504 jkotcon@gmail.com 304-594-3322 (home)