Health Concerns

 

 

The ~1-mile proximity of the Pocahontas County Sanitary Landfill to Pocahontas County High School, situated over porous karst topography, presents a highly contentious public health and infrastructure dilemma.

When debating the proposition that the high school must be relocated due to the landfill's proximity, there are strong arguments on both sides of the issue.

Arguments FOR Relocating the High School

• Imminent and Proven Health Threats: The landfill recently failed a West Virginia Department of Environmental Protection (WV DEP) inspection, which cited the facility for discharging discolored water containing excessive levels of Mercury, Chloride, and dissolved Oxygen. Because the school relies on localized groundwater, these toxins pose a direct threat to the student body.
  
  
• The Karst Hydrogeology Factor: The Dunmore area sits on karst geology, meaning groundwater travels rapidly through underground conduits and caves rather than filtering slowly through dense soil. If toxic leachate breaches the facility, there is virtually no natural filtration barrier between the landfill and the school's water supply.
  
  
• Precedents in West Virginia: Relocating a high school due to environmental hazards is not an abstract concept in the state. Recently, Wetzel County was forced to relocate students from Paden City High School because the surrounding groundwater was severely contaminated. If the aquifer beneath Pocahontas County High School is compromised by heavy metals, the campus would be rendered uninhabitable.
  
  

Arguments AGAINST Relocating the High School

• The Landfill is Reaching End-of-Life: The primary argument against abandoning the high school is that the landfill's threat profile is scheduled to decrease. Engineering estimates recently extended the landfill's usable life only until December 2026. The Solid Waste Authority is already taking steps to transition to a transfer station model rather than expanding local dumping.
  
  
• Prohibitive Economic Costs: Constructing a new, modern high school complex easily costs tens of millions of dollars. For a rural county tax base, abandoning a functional campus is financially devastating.
  
  
• Remediation and Filtration are Cheaper: Instead of moving the school, funds would be better spent addressing the water supply directly. If the wellhead is threatened, it is vastly more cost-effective to install industrial-grade point-of-entry water filtration systems at the school, or pipe in treated municipal water from a neighboring district, than to relocate the entire student body and build new infrastructure.
  
  
• Misplaced Burden of Accountability: Forcing the school to move shifts the burden of the crisis onto the students and the Board of Education. Opponents of relocation argue that regulatory agencies like the WV DEP should enforce strict containment and remediation protocols to force the Solid Waste Authority to fix the environmental hazard at its source.
  
  

Ultimately, the debate hinges on whether the immediate environmental threat of the active landfill outweighs the massive logistical and financial hurdles of abandoning a county's primary educational facility just as the landfill nears its scheduled closure.

WV high school to relocate classes due to contaminated groundwater This local news report details how another West Virginia community recently dealt with the logistical and health challenges of relocating a high school due to a compromised aquifer.

 

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The primary groundwater contaminant that triggered the attempted relocation of Paden City High School in Wetzel County is Tetrachloroethylene, commonly known as PCE or perchloroethylene.

PCE is a highly toxic, volatile organic compound (VOC) and a known human carcinogen that can cause severe damage to the nervous system, liver, and kidneys.

Here is how the contamination occurred and why it threatened the school:

1. The Source: A Legacy Dry Cleaner

The contamination did not originate from a modern industrial accident, but from a former local dry-cleaning business (Band Box Cleaners) located just east of the high school. For years before it closed around the turn of the century, the business dumped PCE and other dry-cleaning solvents, which seeped into the soil and heavily contaminated the town's underlying aquifer. The situation is so severe that the EPA designated Paden City's groundwater as a federal Superfund site in 2022.

2. The Mechanism: Vapor Intrusion

While the town has struggled with PCE in its drinking tap water for years, the specific threat to the high school was vapor intrusion. Because the chemical plume in the groundwater sits directly beneath the school's footprint, the volatile PCE evaporates underground. These toxic chemical vapors—along with other dangerous compounds like Benzene found during testing—were seeping up through the soil, penetrating the concrete sub-slab of the foundation, and entering the indoor air of the school building.

3. The Relocation Order and Legal Battle

Testing revealed that the air inside the school contained multiple toxic compounds at or exceeding levels of concern. In June 2024, the Wetzel County Schools Superintendent declared the risk unacceptable and ordered the immediate closure of Paden City High School, initiating a plan to relocate all students, faculty, and staff to other facilities.

(Note: The situation remains highly contentious; in July 2024, a local circuit judge issued an injunction ordering the school to remain open temporarily while further environmental mitigation, such as specialized ventilation fans, is debated.)

This case serves as a primary example in West Virginia of how legacy groundwater contamination can migrate beneath public infrastructure and force emergency educational disruptions.

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The process of adding a contaminated location to the National Priorities List (NPL)—the EPA’s registry of the most serious hazardous waste sites eligible for long-term Superfund cleanup—is a highly structured, multi-step evaluation.

1.Site Discovery and Preliminary Assessment:

The process begins when the EPA is notified of a potentially hazardous site by citizens, state agencies, or other entities. The EPA enters the site into its database and conducts a Preliminary Assessment (PA). The PA is a low-cost review of existing historical records and data to determine if a threat exists, usually without collecting new physical samples.

2.Site Inspection:

If the PA indicates a potential hazard, the EPA or a state agency conducts a comprehensive Site Inspection (SI). Investigators go into the field to collect soil, surface water, groundwater, and air samples to identify the exact types of toxic contaminants present, their concentrations, and how far they have migrated.

3.Hazard Ranking System (HRS) Scoring:

The EPA uses the physical data from the SI to evaluate the site using the Hazard Ranking System (HRS). The HRS calculates a risk score from 0 to 100 based on the likelihood of a chemical release and the danger it poses to surrounding human populations and sensitive environments via four pathways: groundwater, surface water, soil, and air. To be eligible for the NPL, a site must receive a score of 28.50 or higher.

4.Public Comment and Final Listing:

Sites that meet the 28.50 threshold are officially proposed for addition to the NPL via a notice published in the Federal Register. The EPA opens a 60-day public comment period. After reviewing and responding to all public and stakeholder feedback, the EPA makes a final decision and formally adds the site to the National Priorities List.

While the HRS scoring system is the primary pathway, there are two exceptions. A state or territory can designate a single top-priority site within its jurisdiction to be added to the NPL regardless of its score. Alternatively, a site can bypass the scoring process if the Agency for Toxic Substances and Disease Registry (ATSDR) issues a formal health advisory recommending the removal of people from the area, and the EPA determines that Superfund remedial authority is the most cost-effective response.

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Using federal Superfund money to permanently relocate Pocahontas County High School is highly improbable. While the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) does grant the EPA the authority to fund permanent relocations, the legal and procedural hurdles make it a tool of absolute last resort.

Here is an analysis of why Superfund funding would likely be inaccessible for relocating the high school:

1. The National Priorities List Prerequisite Before any federal Superfund money can be spent on a permanent relocation, the contaminated area must first be formally evaluated, scored, and added to the National Priorities List (NPL). Currently, the Pocahontas County Landfill is facing state-level West Virginia Department of Environmental Protection (WV DEP) violations. Elevating a municipal solid waste landfill from state oversight to a federal Superfund site requires proving an extreme, uncontrolled hazard to human populations, a process that typically takes years of testing and bureaucratic review.

2. The EPA's "Last Resort" Relocation Policy Under EPA policy, permanent relocation is only considered when it is physically impossible to protect human health through engineering controls or when the structures themselves are physically blocking the necessary cleanup equipment. If the primary threat to the high school is groundwater contamination via karst hydrogeology, the EPA's standard operating procedure is to sever the exposure pathway, not move the building.

3. The Cost-Effectiveness Mandate Federal law requires the EPA to choose the most cost-effective remedy that protects human health. Constructing a new, modern high school complex would cost tens of millions of dollars. By contrast, environmental engineering solutions are drastically cheaper. If the school's wellhead became contaminated with landfill leachate, the EPA would mandate and fund an alternative water supply—such as extending municipal water lines to the school, drilling a new well into a deeper, uncontaminated aquifer, or installing industrial-grade point-of-entry water treatment systems (like reverse osmosis and activated carbon filters).

4. The Reality of the Wetzel County Precedent Even in Paden City, Wetzel County—which is a declared federal Superfund site with severe groundwater and vapor intrusion issues—the EPA is not using Superfund money to build a new high school. The decision to close the school and relocate the students was made by the local Wetzel County Schools Superintendent out of immediate caution. The EPA’s actual Superfund mitigation plan for that site involves upgrading the town's water treatment plant (using air strippers to remove chemicals) and installing vapor mitigation systems, not purchasing real estate for new public infrastructure.

In a scenario where the Pocahontas County Landfill severely contaminates the high school's aquifer, any emergency relocation of students would likely fall on the local Board of Education and state emergency funds, while federal environmental funds would be strictly dedicated to filtering the water and capping the landfill.

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In West Virginia, when a rural public school's well is compromised by contamination, providing an emergency drinking water supply (EDWS) is a coordinated effort involving the local school board, the West Virginia Bureau for Public Health (WVBPH), and occasionally federal agencies.

Because rural schools operate as their own Non-Transient Non-Community (NTNC) Public Water Systems, they are required by the EPA to maintain emergency response and contingency plans exactly for this scenario.

If a well fails a test for a serious contaminant like heavy metals or volatile organic compounds from a landfill, the response follows a structured protocol:

Immediate Response: The "Do Not Drink" Order

The WVBPH will immediately issue a "Do Not Drink" or "Do Not Use" order (depending on whether the water is safe for handwashing and flushing toilets, or if skin contact and vapors are also hazardous).

At this stage, the school must immediately secure an alternate supply to keep the facility open.

• Bottled and Bulk Water: The primary immediate response is the distribution of bottled water for drinking and bulk water storage tanks (water buffalos) for food preparation.
  
  
• Water Hauling: The school board may contract certified bulk water haulers to transport clean water from a nearby municipal public water system. The WVBPH enforces strict sanitation rules on these haulers (e.g., Code § 64-18-23.9), requiring that transported water come from an approved public supply, maintain specific chlorine residual levels, and be delivered into sanitized, securely closed holding tanks on the school campus.
  
  

Intermediate Response: Point-of-Use and Mobile Treatment

If the contamination is expected to last weeks or months while a permanent solution is debated, hauling water daily becomes logistically difficult and expensive.

• Point-of-Use (POU) Filtration: With WVBPH approval, the school may install specialized industrial filtration systems at specific taps or water-bottle filling stations. For chemical contaminants like PCE or heavy metals, this usually involves advanced reverse osmosis and granular activated carbon filters.
  
  
• Mobile Treatment Units: For larger schools, state emergency management or the EPA may deploy commercially available mobile water treatment units to temporarily treat the well water before it enters the school's plumbing.
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• In West Virginia, hauling bulk potable water for human consumption is strictly regulated by the Bureau for Public Health under the Office of Environmental Health Services (OEHS). When an emergency like a contaminated school well occurs, any tanker truck brought in to supply drinking water must meet several explicit sanitary requirements.

  These regulations ensure that the water is drawn from a safe source, transported in uncontaminated equipment, and chemically treated to prevent bacterial growth during transit.

  Equipment and Tanker Specifications

  The tanker truck itself must be dedicated to and constructed for safe water transport.

• Documentation and Labeling: The hauler must possess documentation detailing the tank's prior use and reconditioning. The exterior of the tank must be clearly and permanently marked "Drinking Water Only".

• Interior Surfaces: The inside of the tank must be smooth, impervious, and free of corrosion. Any coatings used inside the tank must be non-toxic and explicitly approved for water contact (meeting DW-42 Drinking Water Additives standards) so they do not flake off into the water.

• Access and Ventilation: The tank must have a covered manhole large enough to allow for physical cleaning and interior inspection. It must also feature a protected vent to prevent negative pressure backflow.

• Hoses: All water hoses used for transfer must be rubber or plastic (bearing the NSFpw seal) and protected on the open ends with caps when not in use.

Source and Operational Requirements

Water haulers cannot simply fill up from any available spigot or fire hydrant.

• Approved Source: The water must be drawn from an approved public water system, ideally directly from a treatment plant, at a predetermined point of access agreed upon by the local health department and the water utility. Drawing from dead-end lines or standard fire hydrants is generally prohibited to avoid picking up stagnant water or sediment.

• Chlorination: Before the tank is filled, the operator must add three ounces of 5.25% bleach for every 1,000 gallons of water capacity.

• Residual Testing: Under W. Va. Code R. § 64-18-23.9, the transported water must maintain at least a 1.0 mg per liter (ppm) free chlorine residual at the time of delivery. The driver must physically measure and record this chlorine residual before dispensing the water.

Recordkeeping

To ensure accountability and trace any potential outbreaks, water haulers must maintain a detailed log for at least one year. This log must record:

• The exact source of the water and the point of withdrawal.

• The date and time of both pick-up and delivery.

• The delivery destination and the chlorine residual measurement taken at delivery.

• The name of the driver or responsible person. 

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If a West Virginia rural school pivots to using Point-of-Use (POU) filtration to strip heavy metals (like mercury or lead) and chemical contaminants from a compromised well, they cannot use standard commercial filters. They must use specialized industrial-grade systems certified for health-effect contaminant removal.

To effectively remove heavy metals at the tap (such as at water fountains or kitchen sinks), the two primary technologies are Reverse Osmosis (RO) and specialized Activated Carbon / KDF Filtration.

1. Reverse Osmosis (RO) Systems

Reverse osmosis is considered the most comprehensive and effective POU technology for removing dissolved heavy metals.

• How it Works: RO systems force water under pressure through a microscopic, semi-permeable membrane. The pores in this membrane are so small that water molecules pass through, but larger, heavier metal ions (like mercury, lead, arsenic, and cadmium) are blocked and flushed down the drain as wastewater.
  
  
• Effectiveness: RO systems can eliminate up to 99% of heavy metals, along with other landfill contaminants like chloride, nitrates, and volatile organic compounds.
  
  
• Required Certification: Schools must ensure the RO system holds an NSF/ANSI Standard 58 certification. This is the specific national standard that verifies a POU reverse osmosis system actually reduces the heavy metals to safe levels as claimed.
  
  

2. Specialized Carbon / KDF Filters

Standard carbon filters (like those in a common household pitcher) only improve taste and remove chlorine; they are not sufficient for heavy metals. However, specialized carbon systems can be used if they incorporate specific media.

• Kinetic Degradation Fluxion (KDF): These filters use a high-purity copper-zinc formulation. Through a chemical process called redox (oxidation-reduction), the KDF media exchanges electrons with heavy metal ions (like lead and mercury), bonding them to the filter media and pulling them out of the water. KDF is often combined with a Granular Activated Carbon (GAC) block to catch organic chemicals and VOCs.
  
  
• Required Certification: Any carbon-based or adsorption filter used for heavy metals must carry an NSF/ANSI Standard 53 certification. Standard 53 specifically certifies that a filter reduces a contaminant that has a known health effect (like lead or mercury), rather than just improving taste.
  
  

Important Caveat for Schools: While both technologies work, Reverse Osmosis is generally preferred for severe groundwater contamination because it provides a wider spectrum of protection against unknown landfill leachates (like chloride and emerging chemicals). However, RO systems require significant water pressure and waste a portion of the water to flush the membrane, which must be accounted for in the school's plumbing capacity.

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Based on a review of your Google Workspace documents, there is no specific, confirmed record indicating which exact water filtration method or treatment system is currently installed at Pocahontas County High School.

However, your research documents on local water quality highlight broader challenges and standard practices in the area:

Local Water Quality Context

According to your "Pocahontas County Stream Research" document, the Pocahontas County Public Service District (PSD) has faced significant compliance issues with federal health-based drinking water standards. Specifically, analysis for the quarter ending in June 2024 showed that the system had levels of contaminants like aluminum and manganese that were well above the national average, though not exceeding legal limits. More critically, the utility was cited for a "serious violation" regarding total trihalomethanes (TTHMs)—a group of potentially carcinogenic compounds formed when chlorine reacts with organic matter during disinfection.

Required Treatment for Karst Topography

Your "Pocahontas vs. Greenbrier Karst" document outlines the strict regulatory requirements for treating groundwater in this specific geology. Because the karst conduits allow surface runoff to enter the aquifer rapidly with zero natural filtration, state regulators often designate this water as Groundwater Under Direct Influence (GWUDI) or Surface Water-Influenced Groundwater (SWIG).

This legal designation requires utilities drawing from these aquifers to treat the source with advanced filtration and disinfection equivalent to a surface river intake, rather than treating it like a typical, naturally filtered deep well.

If the high school is on its own well system drawing from the local karst aquifer (or is supplied by the PSD), it would be subject to these stringent surface-water equivalent treatment mandates.