Contaminated Discharges

 

 

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Recent reports indicate that the Pocahontas County Landfill has failed a West Virginia Department of Environmental Protection (WV DEP) inspection, resulting in a "Notice of Violations" that cited 30 separate issues.

According to the inspection report presented at the September 30, 2026, Pocahontas County Solid Waste Authority meeting, the environmental and operational violations include:

• Contaminated Discharges: Discolored water has been discharging from the landfill into streams that ultimately empty into the Greenbrier River. The landfill was found to be discharging excessive levels of Mercury, Chloride, and dissolved Oxygen on at least four occasions between March and July 2026.
  
  
• Improper Chemical Storage: Inspectors found multiple drums of petroleum products at the site lacking secondary containment.
  
  
• Operational Failures: The active working surface of the landfill is larger than permitted, and the daily requirement to cover the trash at the end of the day is not being met.
  
  
• Site Mismanagement: There is no dust control, and loose trash is left laying around, which is being spread outside the facility by wind and birds.

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The West Virginia Department of Environmental Protection gave the Pocahontas County Solid Waste Authority (SWA) Board 20 days to submit a formal response detailing the specific remedial measures they will take to "fully abate" the cited violations.

During their September 30, 2026 meeting, the SWA board took several immediate administrative and security steps while working toward compliance:

• Site Security: The board voted 4-to-1 to install cameras at the landfill's scales and exterior to monitor the grounds. Vice-Chairman Nancy Harris volunteered the temporary use of her personal cameras until the SWA can purchase permanent equipment.
  
  
• Financial Stabilization: The board agreed to apply for a bank line of credit to cover short-term funding shortfalls caused by delays in mailing out the county's "green box" fee bills.
  
  
• Operational Delegation: To streamline administration, the board authorized SWA office staff to pay routine monthly bills prior to waiting for formal board approval.

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Based on the October 2026 reporting of the West Virginia Department of Environmental Protection (WV DEP) inspection, this claim accurately reflects the specific citations issued to the Pocahontas County Solid Waste Authority.

Here is an analysis of the specific elements of this violation and what they indicate about the landfill's environmental impact:

1. The Visual Indicator: "Discolored Water"

Discolored water leaving a landfill site is a primary indicator of leachate escaping containment. Leachate is the liquid that forms when rainwater filters down through decomposing solid waste, picking up dissolved chemicals, heavy metals, and organic matter along the way. In a properly functioning landfill, this toxic "garbage juice" is collected by a liner system and treated. The presence of discolored water in outbound streams indicates a failure in the facility's leachate collection or runoff management systems.

2. The Chemical Markers

The WV DEP identified three specific parameters that were discharged at excessive levels on at least four occasions between March and July 2026:

• Mercury: This is a highly toxic heavy metal. In a municipal landfill, mercury typically originates from improperly disposed household hazardous waste—most commonly older alkaline batteries, fluorescent light bulbs, old thermometers, and electronic waste (e-waste). Mercury does not break down and can bioaccumulate in the aquatic food chain.
  
  
• Chloride: High chloride levels are a classic chemical fingerprint of landfill leachate. It comes from the breakdown of plastics, household cleaning products, human/animal waste, and sometimes water softener salts. Because chloride is highly soluble and does not readily bind to soil, it moves quickly through water systems.
  
  
• Dissolved Oxygen (DO): While aquatic life needs dissolved oxygen, the citation for "excessive" levels is notable. In landfill runoff, the more common issue is a depletion of oxygen because organic waste consumes it. However, excessive or supersaturated DO can occur if nutrient-rich runoff triggers rapid algae blooms in the receiving streams. During the day, massive algae blooms produce excessive oxygen, which can cause gas bubble trauma in fish, before dying off and creating dead zones.
  
  

3. The Pathway: The Greenbrier River

The most significant aspect of this violation is the receiving water body. The streams draining the Dunmore facility area eventually empty into the Greenbrier River. The Greenbrier is the longest untamed (un-dammed) river left in the Eastern United States. It serves as a critical habitat for aquatic life, a major economic driver for county tourism and recreation (such as the Greenbrier River Trail), and a source of drinking water for communities downstream.

The fact that these excessive discharges occurred on at least four separate occasions over a five-month period suggests this was not an isolated spill, but a chronic operational failure during the spring and summer of 2026.

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The Pocahontas County Sanitary Landfill (374 Landfill Road) and Pocahontas County High School (271 Warrior Way) are located remarkably close to one another in Dunmore, West Virginia. Both are situated just off Route 28, separated by roughly one mile.

This geographic proximity presents a serious environmental and public health concern when evaluated alongside the region's specific geology and the recent WV DEP violations.

The Karst Hydrogeology Factor

Dunmore sits on karst topography—a landscape formed by the dissolution of soluble rocks like limestone. Unlike dense clay or sand that can filter and slow down surface water, karst systems are characterized by sinkholes, underground caves, and highly fractured bedrock.

When toxic leachate escapes a landfill in a karst region, it does not slowly filter through the soil. Instead, it can rapidly enter the groundwater and travel miles in a matter of hours or days. This means surface discharges of discolored water easily bypass natural filtration and directly contaminate local aquifers.

High School Water Supply Vulnerability

Rural facilities like Pocahontas County High School typically rely on localized groundwater wells (either on-site or through a local public service district) rather than a distant municipal reservoir. Given the proximity of the two sites and the underlying karst geology, the high school's aquifer is at a severely elevated risk of cross-contamination from the landfill's untreated leachate.

This creates a critical health safety issue for the entire student body, but the risk is especially acute for student-athletes. Players in the high school's football program, who consume massive amounts of water for hydration during late-summer practices, game days, and scrimmages, are on the front lines of exposure if the local well draws from a tainted aquifer.

The Contamination Hazards

If the toxins cited in the WV DEP inspection breach the school's water supply, the hazards are severe:

• Mercury Toxicity: Mercury is a potent heavy metal and neurotoxin. Chronic exposure through drinking water can cause severe neurological and kidney damage, and it is particularly dangerous to developing adolescents.
  
  
• Chloride as a "Tracer": While chloride itself mostly causes water to taste salty or brackish, its presence in groundwater is a classic tracer for landfill leachate. If chloride from the landfill is reaching the school's well, it strongly indicates that other, unmeasured toxic compounds from the municipal solid waste—such as PFAS "forever chemicals," pharmaceuticals, and volatile organic compounds—are traveling right alongside it.

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Rural West Virginia public schools operating their own water systems must adhere to testing regulations enforced primarily by the West Virginia Bureau for Public Health (WVBPH), Office of Environmental Health Services (OEHS). Because a rural school without access to municipal water relies on its own well, it is typically classified as a Non-Transient Non-Community (NTNC) Public Water System.

The primary testing requirements for an NTNC system include:

1. Mandatory Baseline Contaminant Testing

The federal Safe Drinking Water Act, enforced at the state level by the WVBPH, dictates a strict sampling schedule:

• Coliform Bacteria & E. Coli: Tested monthly or quarterly, depending on the specific system configuration, to detect biological contamination from surface water or septic systems.
  
  
• Nitrates and Nitrites: Tested annually, as agricultural runoff and septic system leakage are common in rural areas.
  
  
• Volatile Organic Compounds (VOCs) and Synthetic Organic Compounds (SOCs): Tested according to a scheduled cycle (often every 3–6 years) to detect chemical contaminants, industrial runoff, and pesticides.
  
  
• Inorganic Chemicals (IOCs): Tested on a multi-year cycle for heavy metals, including mercury, chloride, arsenic, and barium—which are critical indicators for landfill leachate or industrial contamination.
  
  

2. Lead and Copper Rule (LCR)

Schools must test for lead and copper at the tap under the EPA’s Lead and Copper Rule.

• Targeted Sampling: Samples must be drawn from specific taps inside the school that are regularly used for drinking and cooking (e.g., water fountains, kitchen sinks).
  
  
• First-Draw Requirement: The water must sit motionless in the plumbing for at least 6 hours before sampling to accurately measure metals leaching from the pipes.
  
  
• Action Levels: The EPA action level for lead is 15 parts per billion (ppb), and 1.3 parts per million (ppm) for copper. Exceeding these triggers mandatory public notification, remediation plans, and often the distribution of bottled water.
  
  
• Note on Lead Funding: West Virginia participates in the EPA’s Lead Testing in School and Child Care Program Drinking Water Grant, which provides funding and training for schools to test for lead.
  
  

3. Public Notification and Recordkeeping

Schools must maintain rigorous records and provide transparency:

• Consumer Confidence Reports (CCR): While NTNC systems are not required to mail an annual water quality report to "customers" like a municipal system, they must keep testing records on file and available for public inspection.
  
  
• Immediate Violation Notices: If a critical contaminant (like E. coli or high nitrates) is detected, the school must issue a public notice within 24 hours (often resulting in a "Boil Water Advisory" or a "Do Not Drink" order).
  
  
• Lead Results: Under the grant program, participants must make lead sampling results available to the public by maintaining a copy in their offices or posting them online.
  
  

Water Bottle Filling Stations

West Virginia law (Code §18-9G-3) has also introduced regulations for the modernization of drinking water access in schools. Any water bottle filling station installed in a public school must dispense filtered water, be touchless, and be regularly maintained. While this does not replace source-water testing, it adds a point-of-use filtration requirement for new drinking stations.

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In West Virginia, the protection of drinking water sources, including the groundwater wells used by rural public water systems, falls under the state's Wellhead Protection Program (WHPP). This program is administered by the West Virginia Bureau for Public Health (WVBPH), Office of Environmental Health Services (OEHS), with the core statutory authority granted by West Virginia Code §16-1-9A.

The WHPP is designed to prevent contaminants from reaching a level that would adversely affect consumer health. For a rural public water system, such as a school's well, the regulations and requirements focus on three major steps:

1. Delineating a Wellhead Protection Area (WHPA)

The first requirement is to establish the physical boundaries of the protection zone. The WHPA is defined as the surface and subsurface area surrounding a public water system's well (or wellfield) through which contaminants are reasonably likely to travel.

• Time-of-Travel Standard: West Virginia specifically delineates the WHPA based on a five-year time of travel. This means the state determines the area from which groundwater could flow and reach the well source within a five-year period.
  
  
• Technical Methodology: The physical boundaries of this area are mapped out using groundwater modeling, available geological technical data, and an assessment of the local hydrogeologic setting (such as karst topographies).
  
  

2. Potential Contaminant Source Inventory

Once the WHPA boundaries are drawn, the water system must identify the risks within that zone.

• Survey Requirement: The regulations require a comprehensive survey of past and present activities performed on all properties located within the delineated WHPA.
  
  
• Identifying Threats: The goal of this survey is to identify Potential Significant Sources of Contamination (PSSC). A PSSC is defined as any facility or activity that stores, uses, or produces substances that could have a significant contaminating impact if released into the source water (e.g., landfills, aboveground storage tanks, industrial sites, or agricultural operations).
  
  

3. Management and Contingency Planning

The final step translates the mapping and inventory work into a functional, actionable plan.

• Mitigation Strategies: The water system must develop strategies to reduce or eliminate the potential threats identified during the source inventory.
  
  
• Emergency Replacement: Crucially, the regulations require the development of both short-term and long-term contingency plans for providing an alternative drinking water supply if the primary source becomes contaminated.
  
  

The WVBPH oversees this process by reviewing and approving the defined WHPAs, tracking the progress of community planning, and providing technical support for the management and contingency phases.

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In West Virginia, calculating the five-year time-of-travel for a Wellhead Protection Area (WHPA) requires sophisticated mathematical modeling. Because groundwater behavior varies drastically depending on the type of geology, the state relies on numerical modeling software to simulate how fast and in what direction water moves underground.

The most prominent tool used for this purpose—both in West Virginia and globally—is MODFLOW, an open-source groundwater modeling program developed by the U.S. Geological Survey (USGS).

However, because West Virginia contains large areas of karst topography (like the area around the Pocahontas County Landfill and High School), standard modeling approaches are not enough.

1. Standard Numerical Modeling (MODFLOW)

For typical aquifers (composed of sand, gravel, or porous sandstone), hydrogeologists use the core MODFLOW program.

• How it Works: The model divides the subsurface into a 3D grid of cells. It assigns specific hydraulic properties (like porosity and permeability) to each cell based on well logs and geological surveys.
  
  
• Time-of-Travel Calculation: Using a companion program like MODPATH (a particle-tracking tool), the model simulates a drop of water or a contaminant entering the ground. It then traces the "particle's" path and calculates exactly how far it can travel through the porous rock toward a pumping well over a five-year period.
  
  

2. The Karst Problem: Conduit Flow Process (CFP)

Standard MODFLOW assumes that water moves slowly and evenly through the microscopic pores of the rock (known as Darcy flow). In a karst landscape like Dunmore, this assumption fails completely.

In karst, water travels through discrete underground rivers, caves, and dissolved limestone fractures (conduits). Contaminants entering a sinkhole can travel miles in a matter of days or hours, rather than inches per year.

To accurately model the five-year time-of-travel in these areas, hydrogeologists use a specialized add-on called the MODFLOW Conduit Flow Process (CFP).

• Dual-Porosity Simulation: CFP allows the model to simulate two different systems at the same time: the slow movement of water through the solid rock matrix, AND the rapid, turbulent flow of water rushing through large underground pipes and caves.
  
  
• Dye Tracing Data: Because you cannot see the underground caves to map them in the software, hydrogeologists physically inject fluorescent non-toxic dyes into sinkholes and measure how fast the dye reaches the local springs or wells. The data from these dye-trace studies is plugged into the CFP model to calibrate the underground flow speeds and validate the time-of-travel.
  
  

3. Conjunctive Delineation

Because karst systems are so unpredictable, the West Virginia Bureau for Public Health sometimes requires an additional layer of modeling called a Conjunctive Delineation. If a well is categorized as drawing "Groundwater Under the Direct Influence of Surface Water" (which is common in karst, where a surface stream might sink underground and rapidly feed a well), the state extends the protection area. The model must account not just for the five-year underground travel time, but also for the surface streams that feed into those sinkholes.

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