In early July, Upper Missouri Waterkeeper submitted comments to the Montana Department of Environmental Quality (DEQ) on the proposed groundwater discharge permit renewal for the Red Creek Sewer facility near Hebgen Reservoir.
The Red Creek Ranch Wastewater Facility, located on the north shore of Hebgen Lake where the lake meets the Grayling Arm, serves commercial retail, rental cabins, and an RV park for tourists and recreationists.
In the comment letter, Waterkeeper raises several concerns with the permit application and DEQ’s analysis. The Red Creek Sewer permit failed to adequately examine the cumulative impacts of nutrient pollution to groundwater that is hydrologically connected to Hebgen Lake, and furthermore, DEQ’s evaluation improperly determined the discharges to be “nonsignificant” without performing the necessary evaluative process under state law.
The first major flaw, that both the Fact Sheet and Environmental Analysis failed to include any evaluation of nutrient pollution fate and transport through groundwater to Hebgen Lake, despite data indicating the receiving groundwater and the lake are hydrologically connected, is particularly concerning for several reasons. Hebgen Reservoir is classified as B-1 high-quality water and has enormous recreational value, yet suffers from persistent eutrophication pollution and cyanobacteria blooms each year, due in part to excessive nutrient loading. The facts described in DEQ’s own documents indicate that the shallow gravel and inorganic alluvium present and lack of absorbent soils that would dilute or chemically alter nutrient wastes means that the wastewater discharge into groundwater from Red Creek Sewer will quickly reach the lake. It’s no secret that Hebgen suffers from harmful algal blooms seasonally that violate water quality standards, and with the addition of thousands of gallons of municipal-scale wastewater pollution that the permit would authorize, water quality in the reservoir is likely to become further degraded.
And although we know additional groundwater discharges contribute to surface water degradation, DEQ failed to even consider the impacts of the Red Creek Sewer’s groundwater discharges on Hebgen Lake and rubber-stamped the discharges as nonsignificant. By law, DEQ’s permitting actions are required to be anticipatory and preventative in assuring citizens’ right to a “clean and healthful” environment, thus it’s inadequate for DEQ to determine nonsignificance based on an incomplete analysis.
Ultimately, Waterkeeper urges DEQ to revisit the permit and reconsider its proposed action. The agency has the authority to withdraw the permit, perform the necessary evaluation of potential impacts on Hebgen Reservoir, evaluate cumulative impacts of nutrient pollution in the watershed, and reach a new properly informed decision under MEPA and the WQA as to whether existing treatment is adequate to assure protection of surface water and to not cause degradation to Hebgen Reservoir.