What’s In Your Water?
A Discussion of Threats To Virginia’s Water Quality
March 27-28, 2015
William and Mary School of Law
Dr. John L. Daniels, P.E.
Professor and Chair
Department of Civil and Environmental Engineering
UNC Charlotte
Sent: Monday, February 10, 2014 2:39 PM
To: Daniels, John
Subject: media query
Here's my question for you or someone you might refer me to: Did Duke violate any
principle of civil engineering in expanding the ash basin in question over a
corrugated-metal stormwater pipe? The pipeline, when it failed, served as a conduit
for ash and wastewater to the river.
From: Daniels, John
Sent: Monday, February 10, 2014 5:31 PM
Subject: RE: media query
Thanks for your note and question.
Appropriately designed, constructed, and maintained corrugated metal pipe can pass
underneath a variety of infrastructure, including ash ponds.
36” RCP
48” CMP
2010 Proposed
Rule
2014 Ruling
2014 NC Coal Ash
Management Act
Comparisons
Site
Date Mass of
Ash
(tons)
PPL
2005 160,000
Martins Creek Station
Delaware River
Bangor, PA
TVA
2008 5,100,000
Emory and Clinch Rivers
Kingston, TN
Duke Energy
Dan River Station
Dan River
Eden, NC
2014 39,000
Volume of
Water
(million
gallons)
100
1,100
27
Coal Combustion Basics
Source: Duke Energy, http://www.dukepower.com/community/learningcenter/generating/coal/coalplants.asp
Coal Combustion Products
Source: USGS, http://pubs.usgs.gov/fs/fs076-01/fs076-01.html
Scanning Electron Microscope Images
Source: J. Daniels
Source: J. Daniels
Duke Energy asks for coal ash leaks to continue
By Jim Bradley
4:40 p.m. EDT, Fri March 13, 2015
CHARLOTTE, N.C. —
Environmental groups said Duke Energy and state regulators are
attempting to legalize potential toxic leaks from controversial coal ash
ponds. New permits for three Charlotte area sites show Duke is requesting
permission to allow multiple leaks to continue.
Duke Energy's coal ash disaster is well-documented.
Last year, a failure at a coal ash pond near the Virginia border sent a toxic
sludge of coal ash into the Dan River.
Since then, Duke Energy has agreed to pay a $100 million fine to the
federal Environmental Protection Agency.
http://m.wsoctv.com/news/news/local/duke-energy-asks-coal-ash-leaks-continue/nkWZD/
Duke Energy asks for coal ash leaks to continue
By Jim Bradley
4:40 p.m. EDT, Fri March 13, 2015
CHARLOTTE, N.C. —
Environmental groups said Duke Energy and state regulators are
attempting to legalize potential toxic leaks from controversial coal ash
ponds. New permits for three Charlotte area sites show Duke is requesting
permission to allow multiple leaks to continue.
Duke Energy's coal ash disaster is well-documented.
Last year, a failure at a coal ash pond near the Virginia border sent a toxic
sludge of coal ash into the Dan River.
Since then, Duke Energy has agreed to pay a $100 million fine to the
federal Environmental Protection Agency.
http://m.wsoctv.com/news/news/local/duke-energy-asks-coal-ash-leaks-continue/nkWZD/
Leachability
“Under the regulations subsequently promulgated, a waste is
considered “hazardous” and subject to regulation under Subtitle
C if it exhibits any one of four characteristics of hazardousness—
ignitability, corrosivity, reactivity, or toxicity. 40 C.F.R. §§
261.11(a)(1), 261.20–24 (2012). The characteristic of toxicity is
“the leaching of toxic residues into surrounding liquid,” Envtl.
Def. Fund, 852 F.2d at 1310, as determined using the Toxicity
Characteristic Leaching Procedure (“Leaching Procedure”) set
forth in EPA Publication SW-846, 40 C.F.R. § 261.24.
Disposal of all other solid wastes is regulated under Subtitle D of
the Act.”
Source: Case 1:12-cv-00523-RBW Document 40 Filed 10/29/13 Page 4 of 35
Not meant to be read…email John if
interested in a copy…
Data Sources:
-Characterization of Coal Combustion Residues from
Electric Utilities – Leaching and Characterization
Data, EPA-600/R-09/151 December 2009
-Lindsay, W. L. 1979. Chemical equilibria in soils. John
Wiley, as cited in Ground Water Issue, Behavior of
Metals in Soils EPA/540/S-92/018
-A Study of the Metal Content of Municipal Solid
Waste, Chemical Science and Technology Laboratory,
NIST (prepared for US DOE), 1998
Solid Phase Concentration
Comparisons
14
Room for
Argument
Aqueous Phase Concentration Comparisons
Evaluating trace elements in groundwater
Background
concentrations:
may exceed
standards
Credit: J. Daniels/B. Langley
Typical Leachate Data
Column Leach Test - Cadmium
100
90
1/6/2004 Samples (Low SPLP)
80
11/12/2003 Samples (High SPLP)
Concentration, ug/L
70
7 Day Composite Samples
60
50
40
30
20
GW Standard = 5 ug/L
10
0
0
5
10
15
Pore Volumes
20
25
30
17
Source: Associated Press. Coal ash, scooped from the Dan River after the Feb. 2 spill
Evaluating Leachability and Transport
Credit: J. Daniels/B. Langley
Numerical Model (MODFLOW):
Fate and Transport Sensitivity Analysis
Boron concentration at compliance boundary
Compliance boundary
Q=?
C=?
Source: http://water.epa.gov/scitech/wastetech/guide/steam-electric/proposed.cfm
Upstream - Dissolved - µg/L
200
150
100
50
0
2/5/2014
2/6/2014
aluminum
arsenic
iron
2/7/2014
copper
Downstream - Dissolved - µg/L
250
200
150
100
50
0
2/5/2014
2/6/2014
aluminum
arsenic
iron
2/7/2014
copper
No NC Water
Quality
standards for
dissolved
metals
Image Credit: http://portal.ncdenr.org/web/guest/dan-river-spill
Upstream - Total - µg/L
8000
7000
6000
5000
4000
3000
2000
1000
0
2/3/2014
2/4/2014
aluminum
Reported as
16,000 µg/L
2/5/2014
arsenic
iron
2/6/2014
copper
Downstream - Total - µg/L
8000
2/7/2014
Applicable
Standard:
Aluminum – 87 µg/L
(aquatic)
Iron – 1000 µg/L
7000
(aquatic health)
6000
5000
4000
3000
2000
1000
0
2/3/2014
2/4/2014
aluminum
2/5/2014
arsenic
iron
2/6/2014
copper
2/7/2014
Upstream - Total - µg/L
50
40
30
20
10
0
2/3/2014
2/4/2014
aluminum
2/5/2014
arsenic
2/6/2014
iron
2/7/2014
copper
Applicable
Standard:
Arsenic – 10 µg/L
Downstream - Total - µg/L
(human health)
50
Copper – 7 µg/L
(aquatic health)
40
30
20
10
0
2/3/2014
2/4/2014
aluminum
2/5/2014
arsenic
2/6/2014
iron
copper
2/7/2014
Parting Comments
Risk and Reuse
You need
all three…
Source
Pathway
Receptor
• March 6, 2014: Superior Court Judge Paul
Ridgeway
– “take immediate action to eliminate sources of
contamination that cause a concentration of a
substance in excess of groundwater quality
standards”
• EPA pre-publication CCR Rule:
– “EPA believes that solid waste activities
should not be allowed to contaminate
underground drinking water sources to
exceed established drinking water standards”
Are we encouraging reuse?
• CAMA Legislative Timelines
• EPA CCR Timelines
• Citizen Suits
Source: http://www.epa.gov/epawaste/nonhaz/municipal/images/waste_hierarchy_green_400pxw.png
ASTM Standard Guides
Dr. John L. Daniels, P.E.
Professor and Chair
Department of Civil and Environmental Engineering
UNC Charlotte
Energy Production and Infrastructure Center - Room 3250
8700 Phillips Road | Charlotte, NC 28223
Phone: 704-687-1219 | Fax: 704-687-0957
jodaniel@uncc.edu | http://coefs.uncc.edu/jodaniel/