Wild Virginia held a webinar this week to teach Virginia citizens on how to oppose permits drafted by the Virginia Department of Environmental Quality (DEQ) that would allow releases of dangerous per- and polyfluoroalky substances (PFAS) to state waters.

The organization is calling on DEQ to hold public hearings to give residents and water users a better chance to share their opinions and concerns about these threats to our environment and our communities. Wild Virginia is also insisting that the permits include monitoring for PFAS and limitations to stop known PFAS releases.

One permit under review is supposed to control polluted stormwater from Fort Belvoir that is discharged to Accotink Creek and other tributaries to the Potomac River. The U.S. Army has found serious contamination of land and water by PFAS in an around its facilities. Those findings make it essential that DEQ impose stringent requirements to protect Virginians. So far, DEQ has failed to even address the known PFAS sources in its draft permit – let alone enforce the law to stop the discharges. DEQ has refused to acknowledge the problem or live up to its legal duty to stop the pollution.

The other permit would allow pollutants to be discharged from a municipal wastewater treatment plant owned by the Arlington County Water Pollution Control Bureau. Data collected by the plant’s owners show that dangerous levels of PFAS have been discharged to Four Mile Run, another tributary to the Potomac River.

ADD YOUR OPPOSITION

We are asking Virginia citizens to submit comments and hearing requests on the Fort Belvoir permit. They are due by 11:59 p.m. Monday. Submit comments to: Susan Mackert, DEQ Northern Regional Office, [email protected]; and [email protected].

Template for comments:

Susan Mackert
Virginia Department of Environmental Quality
Northern Regional Office
[email protected]
[email protected]

Re: Comments and Public Hearing Request – Draft VPDES Permit No. VA0092771 for the U.S. Army Garrison – Fort Belvoir, Discharge of Industrial Stormwater

Dear Susan Mackert:
I am [INTRODUCE YOURSELF – LOCAL RESIDENT/OUTDOORS ENTHUSIAST/ETC] and I am writing to oppose issuance of the Fort Belvoir discharge permit, number VA0092771, as currently drafted because [GIVE #1 REASON FOR OPPOSITION]. I also ask that DEQ hold a public hearing for this permit. My contact information is: [YOUR NAME], [EMAIL ADDRESS AND/OR MAILING ADDRESS], [PHONE #].

I have a strong interest in this permit because [PROVIDE 2-3 REASONS WHY THIS PERMIT AFFECT YOUR INTERESTS. BULLETS BELOW ARE JUST A FEW EXAMPLES. ADAPT THEM TO YOUR SITUATION OR ADD OTHERS THAT ARE PERTINENT TO YOU].

 I care about/use the affected waters – Accotink Creek, its tributaries, downstream waters including the Potomac River and Chesapeake Bay. [DESCRIBE ANY PARTICULAR USES AND/OR VALUES THESE WATERS HAVE FOR YOU].
 It is important to me that toxic PFAS be kept out of the environment and that people and wildlife be protected from them.
 I want and feel I have a right to insist that DEQ live up to its legal responsibilities to control discharges of all pollutants.

The draft permit does not include requirements for monitoring or limitations on the discharges of per- and polyfluoroalkyl substances (PFAS) despite the fact that there are known sources of PFAS at this site, contaminated surface and groundwater, and evidence of past and likely future discharges of these pollutants. Such requirements are necessary and legally required.

Without these requirements, my interests will be harmed [INCLUDE STATEMENT AS TO “HOW AND TO WHAT EXTENT SUCH INTERESTS WOULD BE DIRECETLY AND ADVERSELY AFFECTED BY THE PERMIT.”]
PFAS-containing substances have been and are still being used at Fort Belvoir. The Army’s own study shows that state waters located at Fort Belvoir have already been polluted by high levels of PFAS. This includes contamination of a wetland where high concentrations of PFOS, PFOA, and PFBS have been found. It also includes contamination of groundwater and soils by PFAS, sometimes in extremely high concentrations. PFAS in groundwater and soils will likely affect surface waters. Water quality standards prohibit conditions that would be toxic or dangerous to humans or wildlife and impair uses, including recreation. Additionally, discharges of PFAS in industrial stormwater from Fort Belvoir are likely to cause violations of water quality standards.

To protect my interests, DEQ must amend the permit to require monitoring for PFAS at the outfalls addressed in the draft and at any additional discharge points where PFAS may be present. DEQ must also amend the permit to include requirements to prevent detectable levels of forms of PFAS from being discharged into state waters. Thank you for accepting my comments.

Sincerely,
[YOUR NAME]