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Catawba Riverkeeper Submits Coal Ash Risk Classification Comments for Allen (Lake Wylie) and Marshall (Lake Norman)
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Catawba Riverkeeper Submits Coal Ash Risk Classification Comments for Allen (Lake Wylie) and Marshall (Lake Norman)

DEQ risk classifications will determine whether or not sites have to be cleaned up

Catawba Riverkeeper Submits Coal Ash Risk Classification Comments for Allen (Lake Wylie) and Marshall (Lake Norman)

Coal ash work in the Catawba River basin

The Catawba Riverkeeper Foundation today submitted comments on the draft risk classifications proposed by the North Carolina Department of Environmental Quality.

While the Riverkeeper and SELC lawsuits remain active, the risk classification process is a parallel regulatory action that could also secure cleanups. CRF reviewed thousands of pages of documents submitted in during the past 18 months leading up to this comment period. Thousands of citizens have already commented also imploring DEQ to follow the science and facts and to classify these sites as HIGH or INTERMEDIATE RISK.

While both Allen (Lake Wylie) and Marshall (Lake Norman) were placed by DEQ in a LOW to INTERMEDIATE RISK category, DEQ's own analysis demonstrated that both sites should have been classified as HIGH or INTERMEDIATE RISK. While LOW RISK sites can be left and capped in place, INTERMEDIATE and HIGH RISK sites must actually be cleaned up.

Comments can be read here:

Allen Steam Station (Lake Wylie)

Marshall Steam Station (Lake Norman)

"This is an issue that can continue to linger or can be put behind us, as it has been done throughout South Carolina. Leaving sites like Allen and Marshall in place is waiting for another disaster like what was seen at Kingston, TN, and Dan River, NC. Allen is stacked high on the bank of a populated drinking water reservoir while also sitting below the groundwater table. The best thing for North Carolinians (and downstream South Carolinians), drinking water, the environment, the economy and the greater region that exists downstream is to remove this threat. For these reasons – supported by science, engineering and facts – these sites must be classified as HIGH or INTERMEDIATE RISK."

Conclusion summaries are available below:

Marshall (Lake Norman)

·         There is too much at stake with Lake Norman. It is heavily populated, with even more population relying upon it and downstream reservoirs for drinking water. It is also a major regional economic driver, especially for the four counties that comprise its 520 miles of shoreline. Should Marshall’s coal ash ever collapse into Lake Norman as has happened at other sites in the past, the drinking water and economic crises that would ensue would be on an unprecedented scale.

·         Marshall is one of the largest sites in the state. This is particularly concerning paired with what is perhaps the most population immediately surrounding a coal ash site.

·         Groundwater has been and, even with capping given the substantial portion of the coal ash sitting in groundwater, will continue to be contaminated.

·         People with wells near Marshall who have been told not to drink their water have 10s to 100s of times the hexavalent chromium concentrations both found in municipal water supplies and set by the state as the maximum permissible groundwater concentration (0.07 µg/L).

·         Duke’s groundwater modeling manipulated conditions such that the modeling does not represent a true model of activity at Marshall but rather a fictitiously formulated no mea culpa.

·         Even while some aspects of Duke’s submitted information is incomplete – and this alone should merit at least an INTERMEDIATE RISK classification – the information available still demonstrates the need for a cleanup.

·         Especially given DEQ’s emphasis on floodplains, comprehensive flood modeling must be performed for Lake Norman, and future floodplains and influencing factors must be evaluated. If DEQ still determines Lake Norman will never be allowed to go above full pond, it must consider the impacts on downstream reservoirs and coal ash (i.e., Allen).

·         A cleanup of Marshall would address long-term any concerns with seep discharges in the NPDES permit and would be viewed favorably by the EPA.

·         Evaluating risk inherently must consider past and present behaviors. Duke has had problems monitoring and maintaining its sites in both the past and present. Structural issues have been repeatedly identified by both independent engineers and DEQ. Especially when it has risen to criminal negligence, Duke has lost the privilege of being given any benefit of the doubt.

·         DEQ needs to clarify data discrepancies, notably with regard to Marshall’s size and categorization as a result of size.

·         DEQ needs to revisit its methodology so that it is less reliant on a few “key factors” and more truly considers all factors meant to be relevant as laid out by CAMA (G.S. 130A-309.213(a)). The referenced instance of classification of the Surface Water component, with only the specific factor of the floodplain situation coming out as LOW RISK, demonstrates that other factors/considerations must not matter given that no others were classified as LOW RISK. There also needs to be a HIGH RISK classification option for surrounding population, especially given that loss of life is a threat.

·         Cleanups in South Carolina have been very successful, not raised rates and seen groundwater contamination plummet. Duke is capable of cleaning up Marshall and continuing to thrive as a company for both ratepayers and shareholders.

 

Allen (Lake Wylie)

·         There is too much at stake with Lake Wylie. It is heavily populated, with even more population relying upon it and downstream reservoirs for drinking water. It is also a major regional economic driver. There is also a potential for loss of life with homes immediately across the water from Allen.

·         Allen is one of the largest sites in the state. This is particularly concerning paired with what is perhaps the most population immediately surrounding a coal ash site.

·         Groundwater has been and, even with capping given the substantial portion of the coal ash sitting in groundwater, will continue to be contaminated.

·         People with wells near Allen who have been told not to drink their water have 10s to 100s of times the hexavalent chromium concentrations both found in municipal water supplies and set by the state as the maximum permissible groundwater concentration (0.07 µg/L).

·         Duke’s groundwater modeling manipulated conditions such that the modeling does not represent a true model of activity at Allen but rather a fictitiously formulated no mea culpa.

·         Even while some aspects of Duke’s submitted information is incomplete – and this alone should merit at least an INTERMEDIATE RISK classification – the information available still demonstrates the need for a cleanup. This is especially true when looking at groundwater elevation data and hydraulic gradients that Duke omitted from calculation. These gradients reveal contaminated groundwater moving offsite toward a population with drinking water wells they have been told contain unsafe levels of metals associated with coal ash.

·         Especially given DEQ’s emphasis on floodplains, comprehensive flood modeling must be performed for Lake Wylie, and future floodplains and influencing factors must be evaluated. If DEQ determines Lake Norman will never be allowed to go above full pond as Duke has historically managed that lake’s elevation, it must consider the impacts on downstream reservoirs and coal ash (Allen).

·         A cleanup of Allen would address long-term any concerns with seep discharges in the NPDES permit and would be viewed favorably by the EPA.

·         Evaluating risk inherently must consider past and present behaviors. Duke has had problems monitoring and maintaining its sites in both the past and present. Structural issues have been repeatedly identified by both independent engineers and DEQ. Especially when it has risen to criminal negligence, Duke has lost the privilege of being given any benefit of the doubt.

·         Allen has had dam failures before.

·         DEQ needs to clarify data discrepancies, notably with regard to Allen’s size and categorization as a result of size.

·         DEQ needs to revisit its methodology so that it is less reliant on a few “key factors” and more truly considers all factors meant to be relevant as laid out by CAMA (G.S. 130A-309.213(a)). The referenced instance of classification of the Surface Water component, with only the specific factor of the floodplain situation coming out as LOW RISK, demonstrates that other factors/considerations must not matter given that no others were classified as LOW RISK. There also needs to be a HIGH RISK classification option for surrounding population, especially given that loss of life is a threat.

·         Cleanups in South Carolina have been very successful, not raised rates and seen groundwater contamination plummet. Duke is capable of cleaning up Allen and continuing to thrive as a company for both ratepayers and shareholders.

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