by Brian T. Lynch, MSW
A difference of 5°c in stream water doesn’t sound like much, but for the American Brook Lamprey in the Black River between Hercules and Sunset Lake, it could be the difference between survival and extinction.
Why should their survival matter?
Among the many good reasons, these ancient survivors have one of the most robust immune systems on the planet. Scientists are convinced they hold genetic secrets that might enhance our immune system someday. There is an urgency to study these fish because their numbers are dwindling. They require cool, clear, pollution-free water to survive.
The Hercules permit request is a renewal of an active but obsolete permit from years ago. It allowed Hercules Powder Company to discharge treated wastewater into the Black River, but the property has been vacant for 27 years. It’s being renewed because the proposed redevelopment will need to rebuild the waste treatment plant for the proposed warehouse complex. Among the provisions from the old permit carried over to the new one is the 25°c maximum temperature range for the treated wastewater. The maximum water temperature in which the American Brook Lamprey can survive is 20°c. Because water temperatures in New Jersey are already rising due to global warming, this old temperature restriction is obsolete. New temperature parameters need to be calculated based on our changing climate conditions.
This is where the public can help. During the prior public comments period, the Raritan Headwaters Association made DEP aware of the American Brook Lamprey in the Black River. The harmful impact of carrying over the old temperature limit for treated wastewater was raised, but the revised permit retained the limit. They won’t reconsider this question again in the current public review period without strong public support for reconsideration.
If you agree that the temperature restrictions on wastewater discharged into the Black River should be lower than 25°c, please call or write Bennett Moss at the DEP address below. Here is the DEP memo:
From: Moss, Bennett [DEP] <Bennett.Moss@dep.nj.gov>
Sent: Thursday, May 18, 2023, 7:52 AM
To: Moss, Bennett [DEP] <Bennett.Moss@dep.nj.gov>
Subject: Issuance of the Re-Draft Permit Action for NJPDES DSW NJ0000876
Good morning,
Please find attached the Re-Draft Discharge to Surface Water Renewal Permit Action issued for the following facility as prepared by the Bureau of Surface Water and Pretreatment Permitting:
Permit Class: B – Industrial Wastewater
Permittee: Hercules, LLC
Facility: Hercules, LLC - Kenvil
Township / County: Roxbury Township, Morris County
Program Interest Number: 46431
The Department has attached a PDF version of the re-draft permit to provide you an opportunity to submit formal comments. The public comment period will close on June 16, 2023 as detailed in the re-draft permit cover letter. Notice of this re-draft permit action appeared in the May 17, 2023 DEP Bulletin. The DEP Bulletin is available on the internet at http://www.state.nj.us/dep/bulletin.
Please note that the Department has only issued this permit action by email and a paper copy of the permit will not be mailed. If you have any questions regarding this permit action, please contact me either by e-mail or by phone at (609) 292-4860.
Thank you,
Bennett
Bennett Moss, Environmental Specialist
Bureau of Surface Water & Pretreatment Permitting
Division of Water Quality
NJ Dept. of Environmental Protection
Phone: (609) 292-4860
Re-Draft Permit Renewal for NJPDES DSW NJ0000876.pdf
2688K View as HTML Scan and download
The Hercules permit request is a renewal of an active but obsolete permit from years ago. It allowed Hercules Powder Company to discharge treated wastewater into the Black River, but the property has been vacant for 27 years. It’s being renewed because the proposed redevelopment will need to rebuild the waste treatment plant for the proposed warehouse complex. Among the provisions from the old permit carried over to the new one is the 25°c maximum temperature range for the treated wastewater. The maximum water temperature in which the American Brook Lamprey can survive is 20°c. Because water temperatures in New Jersey are already rising due to global warming, this old temperature restriction is obsolete. New temperature parameters need to be calculated based on our changing climate conditions.
This is where the public can help. During the prior public comments period, the Raritan Headwaters Association made DEP aware of the American Brook Lamprey in the Black River. The harmful impact of carrying over the old temperature limit for treated wastewater was raised, but the revised permit retained the limit. They won’t reconsider this question again in the current public review period without strong public support for reconsideration.
If you agree that the temperature restrictions on wastewater discharged into the Black River should be lower than 25°c, please call or write Bennett Moss at the DEP address below. Here is the DEP memo:
From: Moss, Bennett [DEP] <Bennett.Moss@dep.nj.gov>
Sent: Thursday, May 18, 2023, 7:52 AM
To: Moss, Bennett [DEP] <Bennett.Moss@dep.nj.gov>
Subject: Issuance of the Re-Draft Permit Action for NJPDES DSW NJ0000876
Good morning,
Please find attached the Re-Draft Discharge to Surface Water Renewal Permit Action issued for the following facility as prepared by the Bureau of Surface Water and Pretreatment Permitting:
Permit Class: B – Industrial Wastewater
Permittee: Hercules, LLC
Facility: Hercules, LLC - Kenvil
Township / County: Roxbury Township, Morris County
Program Interest Number: 46431
The Department has attached a PDF version of the re-draft permit to provide you an opportunity to submit formal comments. The public comment period will close on June 16, 2023 as detailed in the re-draft permit cover letter. Notice of this re-draft permit action appeared in the May 17, 2023 DEP Bulletin. The DEP Bulletin is available on the internet at http://www.state.nj.us/dep/bulletin.
Please note that the Department has only issued this permit action by email and a paper copy of the permit will not be mailed. If you have any questions regarding this permit action, please contact me either by e-mail or by phone at (609) 292-4860.
Thank you,
Bennett
Bennett Moss, Environmental Specialist
Bureau of Surface Water & Pretreatment Permitting
Division of Water Quality
NJ Dept. of Environmental Protection
Phone: (609) 292-4860
Re-Draft Permit Renewal for NJPDES DSW NJ0000876.pdf2688K View as HTML Scan and download
Is the DEP the responsible entity to review temperature concerns in these type of permits? If the permit is granted, isn’t the wastewater itself the larger impact/threat to this and potentially other species who need clean water to survive?
ReplyDeleteFrom an article: “ Water temperature is an important physical property of every lake. Many plants, animals, and other organisms flourish only in a specific range of water temperatures. Temperature can also affect certain aspects of water quality. For example, higher temperatures promote the growth of algae and bacteria, but they also reduce levels of dissolved oxygen in the water, which can negatively affect the growth and productivity of other aquatic life.” The NJDEP does have responsibility to monitor stream water temperature changes caused by human activity. It is an important component to safeguard the biota in a watersheds. There are lots of toxins and metals on the Hercules site that can be harmful also, but I lack the background to evaluate how they are addressed in the permit.
ReplyDelete