20070812 Ver 1_00 Rodgers Report_20080502

Review of Data and Proposals
Regarding Water Quality in Badin
Lake, NC - Risks and Dam or
Hydropower Operations, Prepared by
John H. Rodgers, Jr., Ph.D. for Stanly
County, North Carolina
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REVIEW OF DATA AND PROPOSALS REGARDING WATER QUALITY IN
BADIN LAKE, NC - RISKS AND DAM OR HYDROPOWER OPERATIONS
A Report Prepared for
Stanly County
By
John H. Rodgers, Jr., Ph.D.
102 Santee Trail
Clemson, SC 29631
and
Department of Forestry and Natural Resources
Clemson University
Clemson, SC 29634
April 29, 2008
I. Introduction
I have been asked to assist Stanly County, North Carolina in evaluating water
quality issues arising from the proposed Federal Energy Regulatory Commission
("FERC") relicensing of the hydropower dam on Badin Lake in Stanly County (and
related facilities) . In particular, I have been asked to present my views on the proposed
issuance of a "Section 401 water quality certification" (the "Section 401 certification") to
Alcoa Power Generating, Inc. ("APGI") pursuant to the Federal Clean Water Act. I am
thoroughly familiar with water quality conditions and how they can be created or
affected, positively or negatively, by hydropower dam operations. I have prepared this
report to provide a brief overview, based on my experience, of my conclusions at this
time.
The report is divided into two parts. First, it identifies and briefly discusses
significant water quality issues arising from or affected by dam operations associated
with hydropower production from the Badin Lake (Narrows Lake) project managed by
APGI. These issues were not considered and surely not resolved in the relicensing
settlement agreement (RSA) process or the Section 401 certification process. They
warrant far more investigation.
Second, it presents a scientific review of some of the documents that were or
should have been utilized in the Section 401 certification process. In particular, the
report identifies issues raised by those documents, and presents reasons why they
highlight conditions that should be carefully considered before deciding whether and on
what terms a Section 401 certification would be issued for this project. In a few cases,
the report describes why the conclusions reached by certain of the documents are not
reliable with respect to evaluating actual water quality and the effect of dam operations.
Water quality in reservoirs, tailwaters and receiving systems is required to meet
Class C water quality standards for NC surface waters. This water should be suitable for
aquatic life propagation and maintenance of biological integrity, wildlife, secondary
recreation and agriculture. Water in Baden Lake must also meet Class B standards,
which includes primary recreation. Finally, the water must meet Class WS-IV standards
for domestic water supply, which basically means a source of water supply for drinking,
culinary, or food-processing purposes for those users where a more protective WS-I, WS-
II or WS-III classification is not feasible and any other best usage specified for Class C
waters. In considering these standards and uses, a primary concern relates to dam
operations that have the potential to, and likely do, adversely impact downstream water
quality, exacerbate existing, historic water quality problems and/or affect water quality
upstream of the dam. Those problems are both abiotic as well as biotic. The importance
of the connection between hydropower operations, the FERC process and the watershed
is recognized and addressed in the document Yadkin Project, FERC No. 2197 NC,
Wetland and Riparian Habitat Assessment Final Study Report by Normandeau and
Associates, Inc. (2005a). Several of the problems arising from dam operations were also
noted in the report by Normandeau and Associates, Inc. (2005b), Yadkin Project, FERC
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No. 2197 NC, Yadkin Water Quality Monitoring Report, Final Study Report (2005).
Other problems and concerns were identified in other cited reports (see attached
References). A few (but certainly not all) of these problems are presented below. These
water quality problems, and the dam operations that can and do affect them, were
not addressed or resolved in the FERC relicensing process or the Section 401 review
(RSA; Deposition of John R. Dorney - April 14, 2008).
U. Materials reviewed
I have included an extensive bibliography of reference materials that support the
conclusions presented herein. With respect to water quality conditions existing in or
around Badin Lake, I reviewed in particular the following materials, many of which were
available either through the RSA process or from the North Carolina Division of Water
Quality's ("DWQ's") own research and investigation of Badin Lake and the surrounding
watershed. I understand that most of these materials were available to DWQ in the
Section 401 process, but it does not appear from the Section 401 certification that they
were reviewed by DWQ in any detail:
1. "Characterization of the Toxicity and Bioavailability of Polycyclic Aromatic
Hydrocarbons in Aquatic Sediments from Badin Lake" by The RETEC Group, Inc.,
Ithaca, NY (February 16, 2007)
2. RCRA Facility Investigation Report - Volume I of II and Volume II of II, ALCOA
Badin Works, Badin, NC (March 2001) by MFG, Inc., Pittsburgh, PA
3. Yadkin-Pee Dee River Basinwide Water Quality Plan (March 2003) (NCDENR
Report)
4. Yadkin-Pee Dee River Basin Basinwide Assessment Report Whole Effluent Toxicity
Program (2002-2006) (NCDENR Report)
5. Yadkin-Pee Dee River Basin Ambient Monitoring System Report (2002-2006)
(NCDENR Report)
6. Lake and Reservoir Assessments - Yadkin-Pee Dee River Basin (2007) (NCDENR
Report)
7. Badin Lake Swim/Picnic Area and Badin Boat Access Sediment Assessment, Stanley
County,NC by Environmental Services, Inc., Raleigh, NC
8. Fish Sampling Work Plan - Narrows Reservoir, Badin, NC by the URS Corporation,
Franklin, TN (December 2007)
9. Sediment Fate and Transport Report (Draft) by Normandeau Associates, Inc. and PB
Power (December 2004)
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10. Wetland and Riparian Habitat Assessment (Draft) by Normandeau Associates, Inc.
(February 2005)
11. Invasive Exotic Plan Pest Species (Draft) by Normandeau Associates, Inc. (February
2005)
12. Rare, Threatened and Endangered Species Survey (Draft) by Normandeau Associates,
Inc. (February 2005)
13. Transmission Line and Project Facility Habitat Assessment (Draft) by Normandeau
Associates, Inc. (February 2005)
14. Yadkin Reservoir Fish and Aquatic Habitat Assessment (Draft) by Normandeau
Associates, Inc. (March 2005)
15. Yadkin Tailwater Fish and Aquatic Biota Assessment (Draft) by Normandeau
Associates, Inc. (March 2005)
16. Regional Recreational Evaluation (Final Study Report) by ERM (April 2005)
17. Yadkin Reservoir Fish and Aquatic Habitat Assessment (Final) by Normandeau
Associates, Inc. (June 2005)
18. Yadkin Tailwater Fish and Aquatic Biota Assessment (Final) by Normandeau
Associates, Inc. (June 2005)
19. Wetland and Riparian Habitat Assessment (Final) by Normandeau Associates, Inc.
(June 2005)
20. Yadkin Water Quality Monitoring Report (Final) by Normandeau Associates, Inc.
(August 2005)
21. Recreational Use Assessment (Final) by ERM (October 2005)
22. Yadkin Habitat Fragmentation Study Maps (Final) by Normandeau Associates, Inc.
(May 2006)
23. Yadkin River Goldenrod Survey (Final) by Normandeau Associates, Inc. (September
2006)
III. SijZnificant Water Quality Issues (not an exhaustive list)
As noted, this report presents only a brief review of the more significant of the
numerous water quality matters at issue (or that should have been at issue) in the RSA
and the Section 401 certification review. Additional review and analysis would be
necessary to evaluate theses matters properly. There is, however, substantial
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documentation of (i) the presence of actual, adverse water quality conditions, and (ii) the
fact that these adverse conditions are and can be caused or affected by dam operations.
Among the most serious of these matters are as follows:
1. Sediment release and transport impacting ecological resources (e.g. ammonia
released from anoxic sediments - p.76 Normandeau and Associates, Inc.
(2005b))
The evaluation prepared by Normandeau and Associates, Inc. (2005b; p.76)
pointed to releases of potentially toxic levels of ammonia during dam operation. The
ammonia arises from the anoxic sediments upstream, and timing of releases as well as the
magnitude of releases exacerbates this problem. The criticality of timing releases and
recognition of strong stratification in this reservoir were not included in the relicensing or
Section 401 certification processes. Also unacknowledged, numerous other toxic
elements (e.g. mercury, iron, manganese) and compounds (e.g. PCBs, cyanide
complexes, PAHs) are likely mobilized during periods of stratification by dam operations
and transported downstream (Owens et al. 2005). Owens and coauthors (2005) pointed
out that fine grained sediments can be readily transported in rivers, even those interrupted
by dams. These fine sediments have a relatively large surface area for sorption of
hydrophobic or relatively water insoluble chemicals, such as PCBs and PAHs. Therefore,
movement of contaminants downstream from a reservoir through dam operations is
common. For this specific situation, contaminants of interest in a sediment study
(Review of RCRA Facility Investigation Report - Volume I of II and Volume II of Il,
ALCOA Badin Works, Badin, NC (March 2001) by MFG, Inc., Pittsburgh, PA)
conducted in Badin Lake included cyanide (ground water and soil - free cyanide and Fe
cyanide complexes, hexacyanoferrate complexes, ferro-ferric cyanides), arsenic,
benzo(a)anthracene, benzo(a)pyrene, benzo(a)fluoranthene, dibenzo(a,h)anthracene,
indeno(1,2,3-ed)pyrene, benzene and trichloro ethylene. Sediment data were collected
from Badin Lake (p.100) and the analyte concentrations were compared with industrial
soil RBC's. Although this comparison was deemed conservative, it is based on solely
human contact and in fact understates the potential for ecological harm. For this reason it
is a common practice to also consider potential ecological effects by initially comparing
the analyte concentrations with screening values for sediments (e.g. NOAH). Based upon
the NOAA Sediment Screening values (used to indicate such potential adverse ecological
effects), arsenic, PCBs, benzo(a)pyrene as well as several other organic compounds in
Badin Lake exceeded concentrations indicating the need for additional investigation to
evaluate fully the probable ecological harm (Tables 4-58, 4-59). Total PAH
concentrations in sediments from Badin Lake (Table 3-1, "Characterization of the
Toxicity and Bioavailability of Polycyclic Aromatic Hydrocarbons in Aquatic Sediments
from Badin Lake" by The RETEC Group, Inc., Ithaca, NY (February 16, 2007); 475 -
1,390 mg/kg) exceeded NOAA Sediment Screening Values for ecological effects.
Concentrations of individual organic analytes were also well in excess of NOAA
Sediment Screening Values for ecological effects (Table 4-1, The RETEC Group, Inc.,
Ithaca, NY (February 16, 2007). In addition to the ecological harm, analyte
concentrations in sediments such as benzo(a)pyrene (a potent carcinogenic PAH) pose a
probable risk for swimmers in Badin Lake.
Clearly, several contaminants in Badin Lake may be mobilized and transported by
dam operations posing risks to humans and biota downstream. These contaminants can
be mobilized in the hypolimnion or bottom waters of the lake and move downstream
through the dam in solution (e.g. ammonia, sulfides) or as suspended solids or
particulates (e.g. PCBs, mercury, etc.). Some of these problems are pointed out in the
Normandeau and Associates, Inc. Report (2005b).
The draft study report on sediment fate and transport (Normandeau Associates,
Inc. and PB Power 2004) clearly states that this reservoir (Badin Lake) is located in
proximity to highly erodable soils. Even though the reservoir serves as a significant
sediment trap (-90%), a fraction of the millions of tons transported each year is passed
along through the outlet structures. The report focuses solely on the volume of sediment
or solids transported through structures. On p. iv of the report, the authors clearly state
that dam operations influence sediment transport and that turbidity levels are often
greater than water quality standards. Importantly, this report is focused solely on the
quantity of sediments transported, not the quality (or load of associated toxic materials).
2. Spread and impact of an invasive species (i.e. Lyngbya wollei)
The invasive algal species, Lyngbya wollei, has colonized Badin Lake sediments
and will likely spread throughout this reservoir. The scientific literature on Lyngbya
wollei is replete with information regarding potential adverse effects that this noxious
filamentous cyanobacterium can cause (e.g. see literature cited below). These adverse
effects include impeding navigation, clogging water intakes, producing taste and odor
problems in water and fish, altering ecosystem structure and extirpating sensitive aquatic
species. Lyngbya has the ability to produce dermatitis toxins (e.g. Aplysiatoxins
[Mynderse et al., 1977; Osborne et al. 2001; Briand et al., 2003]; Lyngbyatoxin - A
[Cardellina et al. 1979; Stafford et al. 1992; Osborne et al. 2001]; lipopolysaccharides
[Carmichael 1994]), neurotoxins and paralytic shell fish poisons (PSPs) (e.g. Saxitoxins
[Carmichael et al. 1997b; Yin et al. 1997], Ichthyotoxin [Mastin et al. 2002], Antillatoxin
[Collins 1978; Berman et al. 1999] and Invertebrate toxins [Snell 1980; Camancho &
Thacker 2006]. This is a serious and growing problem that can be exacerbated or
mitigated by dam operations that should not be ignored. Ignored, this problem can grow
to impede hydropower operations. Indeed, the US Army Corps of Engineers has
conducted research indicating the potential adverse effects of this species on hydropower
production and the effects of dam operations on the growth and spread of this species
(e.g. Doyle and Smart 1998). Seasonally, Lyngbya wollei forms floating mats that can be
entrained and transported downstream through the dam spreading the problem. By
fluctuating water depth through dam operation during the growing season, growth of this
noxious alga can be reduced.
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3. Release of suspended solids impacting drinking water and human health -
e.g. benzo-a-pyrene
Several reports or sources listed sediment release from the hydroelectric operation
as a concern. That concern should include both quantity and quality of sediments from
Badin Lake. It is probable that the smaller and lighter (lower specific gravity) particulates
are suspended and discharged or released downstream. The smaller diameter particulates
and the organic particulates sorb and transport disproportionately large amounts of PAHs,
PCBs and other relatively water insoluble compounds. Clearly, operation of the dam for
hydropower production can influence the transport and loading of these toxic materials
downstream (Owens et al. 2005). As noted above, hydrophobic or relatively water
insoluble toxic chemicals sorb readily to small particulates which are transported
downstream through dam operations. Data contained in the study "Kadin Lake
Swim/Picnic Area and Badin Boat Access Sediment Assessment, Stanly County, North
Carolina" by Environmental Services, Inc., Raleigh, NC, indicate the potential for
adverse effects of sediments both upstream and downstream. Although somewhat limited
in scope, the results from this study indicate significant contamination in the sediments at
the Badin Lake Swim/Picnic Area and the Badin Boat Access site relative to the
reference site. Importantly, arsenic, PCBs (Arochlor 1242), and SVOCs
(benzo(b)fluoranthene and benzo(a)pyrene) were measured at concentrations that can
pose significant human health risks. Several analytes such as arsenic in sediments at the
study site exceeded concentrations that indicate potential for adverse ecological effects to
biota. Further, analytes (concentrations and distribution) such as fluoranthene and
anthracene indicate an ongoing source. The lack of detection of selenium in any sediment
sample is both perplexing and troubling. Selenium is a common element found in
sediments and is essential for plant and animal life. Although selenium may be present at
a relatively low concentration, it should be detectable by any reasonably sensitive
analytical technique. The study authors recommend a more comprehensive study.
Although reservoirs are inherently sediment traps, these sediments can be transported
from reservoirs during turnover or destratification and dam operations should be
cognizant of that situation. During periodic intense rainfall events, particulates are
suspended in reservoirs in the southeast. Sediments and solids are also suspended
temporarily during the phenomenon known as turnover when the water temperature in the
reservoir is relatively uniform. These are specific occasions when sediments can be
transported downstream through dam operations. These are also opportunities to
minimize potential impacts of these sediments on downstream areas. There was no
apparent consideration of this information in the relicensing or Section 401 certification
processes.
4. Dissolved oxygen profiles downstream and oxygen demanding sediments
Several sources and reports cited oxygen profiles downstream as intensely
influenced by dam operations. Indeed, plans were proposed to implement physical means
of oxygen entrainment from the atmosphere as water is released during hydropower
production as part of the relicensing agreement (RSA). This is analogous to putting a
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bandaid on skin cancer. As noted in specific reviews of documents below, the sediments
contained in Badin Lake are exceptional in terms of their organic carbon content and their
oxygen consumption (sediment oxygen demand) based upon all available data. Since
oxygen is sparingly soluble in water, the oxygen supplied must exceed the oxygen
demand of the sediment released in order to achieve a net gain in oxygen concentration
downstream. There are no measurements of the oxygen demand exerted by the sediments
released downstream during hydropower operations. Nor are there measurements of
benthic invertebrates downstream. Operation of the dam and releases of hypolimnetic
waters can obviously impact the downstream biota through altering oxygen
concentrations and availability. There is no assurance that the proposed "fix" for the
dissolved oxygen conditions in the downstream areas will actually bring the discharged
water into compliance with water quality criteria (what is the schedule for compliance?,
what are the consequences for noncompliance?, etc.).
5. Impact of dam operations on release of toxic elements and compounds
downstream - sulfides, iron, ammonia, phosphorus, mercury, PAHs and
possibly arsenic, cadmium, lead, selenium, copper and zinc
Control of biogeochemical cycling, speciation and stability of a variety of
potentially toxic elements associated with sediment in Badin Lake is strongly influenced
by oxidation-reduction (redox) conditions in the reservoir. Due to stratification or
layering and deoxygenation of water in the lake (which is in part controlled by dam
operations as well as apparent contaminated sediments), potentially toxic elements such
as nitrogen (as ammonia), sulfur (as sulfides) and mercury that normally partition to
sediments are released. Redox conditions in the reservoirs, in turn, can be affected
significantly by dam operations (e.g. through drawdown of the hypolimnion, storage of
water, etc.). Although releases of ammonia and mercury were identified in reports as
problematic or potentially problematic, there was no evidence that the other issues (e.g.
phosphorus or sulfide release, or the impact on PAHs and metals) were even considered.
Currently, extant data do not permit accurate appraisal of the potential risks from these
sources.
6. Impact of dam operations on eutrophying nutrients in the lake and releases
downstream (e.g. phosphorus, iron)
Dam operations have obvious effects on upstream pool levels. In turn, dam
operations and pool levels influence the development of stratification and the level of the
hypolimnion. The hypolimnion permits the sediments to remain anaerobic for extended
periods of time. During the period of development of anaerobic sediments, elements that
can contribute to eutrophication, such as phosphorus and iron, are mobilized and released
downstream through the dam. These are relatively well known biogeochemical processes
that occur in aquatic systems and should have been considered in the relicensing and
Section 401 certification processes (RSA).
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7. Bioconcentration, bioaccumulation and potential biomagnification of toxic
elements and compounds in biota downstream (as well as in the lake) with
adverse impacts on ecological resources as well as human health.
Elements, such as mercury, and compounds, such as PCBs, have the propensity
for exceptional bioconcentration, bioaccumulation, and biomagnification. As indicated
above and in the text below, the mobility and bioavailability of these materials can be
exacerbated by dam operations. Although a potential problem was recognized upstream
in the reservoir (see review of fish tissue study below), there was no similar proposal to
examine the downstream areas that are subject to exposures through dam operations. The
magnitude and extent of this problem remains unknown at this time.
8. General water quality for fish spawning and support of aquatic life
downstream (e.g. temperature, pH, dissolved oxygen, etc.)
The estimated average hydraulic retention time of water in Badin Lake is about
two days. If that estimate is accurate the hypolimnetic and sediment oxygen demand must
be exceptionally large. Dissolved oxygen depleted waters are frequently released during
hydropower generation and dissolved oxygen downstream is often at or below state
standards. Problems with low dissolved oxygen in tailrace and discharge of nutrients and
algae are frequently cited in reports (Normandeau and Associates 2005b) as are
accumulations of sediments, nutrients and algae in areas downstream. These are
conditions that cause adverse effects on fisheries downstream and can be alleviated by
dam operations. In fact, the draft report on fish and aquatic biota (Normandeau
Associates, Inc. 2005) noted a decline in mussels and fish in tail waters below the dam on
Badin Lake (as did the report on the Yadkin tailwater fish and aquatic biota assessment
(2005)). These issues were not adequately addressed in the relicensing or Section 401
processes. The potential for proposed modifications of equipment to resolve these
problems is unknown and unspecified. The compliance deadline and penalties for water
quality violations should have been specified.
I also note that the report on wetland and riparian habitat assessment
(Normandeau Associates, Inc. 2005) specifically stated that reservoir operations such as
timing and magnitude of drawdown could adversely impact both upstream and
downstream vegetation (especially Justicia americana).
9. Strong seasonal stratification and lack of fluctuating water levels in Badin
Lake exacerbates water quality problems downstream and upstream.
The Normendeau Report (Normandeau and Associates 2005b) identified
development of strong seasonal stratification in Badin Lake over five years of sampling.
Interestingly, only three to four stations in Badin Lake were sampled with limited
sampling of the downstream areas. The lack of fluctuation in water levels in Badin Lake
probably contributes significantly to observed water quality problems. The hypolimnetic
release for hydropower production contains toxic concentrations of ammonia and likely
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sulfide as well as other elements and compounds that adversely affect downstream
aquatic life. Clearly, sediment contamination and oxygen demand are contributing factors
that could have been addressed in the Section 401 certification.
10. Water quantity is coupled with quality and drought plans should be coupled
with water quality issues.
Drought planning to improve or maintain water quality downstream of the Badin
Lake hydropower facility is clearly inadequate for relicensing. The factors presented in
items 1-9 (above) have not been considered or included in this process. Thus, this
important water resource for the State of North Carolina has not been adequately
protected. Not only have important water quality issues not been considered, ongoing
problems have not been resolved. And "risk balancing" or risk management has not been
accomplished in the relicensing or Section 401 certification processes.
Clearly, dam operation for hydropower production can 1) adversely impact water
quality both upstream and downstream from the dam; 2) exacerbate existing problems
and situations; 3) help to avoid problems both upstream and downstream; and 4) help to
solve problems both upstream and downstream. The relicensing and Section 401
processes are an opportunity to address issues in this important water resource for the
State of North Carolina.
IV. Technical Review of Selected Reports
This section of the report contains scientific reviews of several documents that
were available to DWQ during the FERC relicensing and Section 401 certification
processes or should have been evaluated during the process deliberations. The list of
documents was not intended to be exhaustive, but was intended to represent strategic
information that could and should have been considered by the agency in deciding
whether to issue a Section 401 certification as well as the conditional terms. Observations
offered here are relative to water quality conditions that can be impacted (both positively
and negatively) by dam operations on Badin Lake for hydropower production.
Review of "Characterization of the Toxicity and Bioavailability of Polycyclic
Aromatic Hydrocarbons in Aquatic Sediments from Badin Lake" by The RETEC
Group, Inc., Ithaca, NY (February 16, 2007)
The stated objective of this report was to assess the bioavailability of polycyclic
aromatic hydrocarbons (PAHs) in sediments of Badin Lake, North Carolina, adjacent to
the Alcoa Badin Works (aluminum smelter). The two goals of this project were: 1) to
determine if the PAHs in the sediments are bioavailable and toxic to benthic aquatic
organisms, and 2) to evaluate whether the measurement of PAHs in sediment pore water
using solid phase microextraction (SPME) or rapidly released PAHs in sediment using
supercritical fluid extraction (SFE) could be used to predict PAH bioavailability and
toxicity.
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This project and study design are fundamentally flawed in terms of achieving the
stated goals and objective. The scientific support for this conclusion is presented below.
Although samples of sediments were collected from 22 sites in Badin Lake only
12 were analyzed as planned (Badin Lake = about 5,350 acres with about 115 miles of
shoreline). Water characteristics were also measured in situ during the sediment
sampling event. The sediment samples from a site were homogenized and subsequently
analyzed for a series of PAHs as well as cyanide species. Based on results from the
chemical analyses, some sediment samples (12) were selected for laboratory toxicity
testing. The homogenization of the sediments and subsequent reporting of no or low
concentrations of low molecular weight PAHs is troublesome (but not surprising). The
most bioavailable and acutely toxic fraction of the PAHs that may have been in the
sediments had ample opportunity to volatilize during the homogenization procedure.
Thus, these samples would not be representative of the potential sediment toxicity in the
reservoir (i.e. in situ). In spite of this irregularity in sampling, total PAH concentrations in
sediments from Badin Lake (Table 3-1; 475 - 1,390 mg/kg) exceeded NOAA Sediment
Screening Values for ecological effects. Concentrations of individual organic analytes
were also well in excess of NOAA Sediment Screening Values for ecological effects
(Table 4-1).
In order to assess the toxicity of sediments, laboratory toxicity testing was
conducted with sediment samples from Badin Lake. Survival and growth of Chironomus
tentans (a midge) and Hyalella azteca (an amphipod) were measured in 10-day and 28-
day exposures, respectively. The sediment samples were characterized (e.g. particle size,
organic matter content, etc.) since these are factors that can strongly influence the
outcome of laboratory toxicity testing. At least one sample of the sediments that was
tested had 1,690 mg/kg of PAHs. Other sediment samples had exceptional concentrations
of "organic carbon" (ie. > 2-3 %); however these high concentrations of organic carbon
were dismissed as pyrogenic. No adverse effects on the sensitive sediment test organisms
(C. tentans and H. azteca) were reported in this study. The information provided in this
report would cause one to expect massive toxicity (i.e. adverse effects on test animals).
The reported results would cause one to question the conduct of the study.
The details provided in the body of the report as well as the appendix contain
more troubling information regarding the conduct of the study. First, the sediment
toxicity tests were conducted as flow-through or renewal; that is, the water overlying the
sediments in these tests was renewed either continuously or daily. If the test organisms
did not burrow into the sediments, they could avoid exposure to the PAHs contained in
those sediments. Thus, they would not be affected by those PAHs. Careful researchers
would have noted this avoidance reaction, and the testing laboratory (US Army Corps of
Engineers, Vicksburg, MS) did so in this case (p.4-5). This means that these test
invertebrates were committing ecological "suicide" by failing to burrow in the sediments
to avoid exposure to both PAHs and predators. The failure to find effects in such a
situation is not reassuring or convincing.
The pH of the laboratory water used in renewal of these tests was -7.7 - 8.4 and
dissolved oxygen was > 8 mg/L based on the appended data. Using dissimilar water in
these sediment toxicity tests and decoupling the sediment from its overlying water can
yield results that have no predictive value in terms of translation to the field site. The
field data (Table 2-2) indicated that the in situ water pH was 6.1-6.9; this is a significant
difference (more than an order of magnitude difference in hydrogen ion concentration)
and surely altered the potential to observe toxicity in these sediments. To make matters
worse, the researchers apparently aerated the tests constantly throughout the exposure
period to maintain sufficient oxygen for survival of the test animals. The fact that
aeration was required is not surprising given the reported organic matter (>6%) in some
samples collected for PAH analysis. However, the aeration would serve to further mask
or confound the ability of these tests to detect effects of PAHs. It is likely that PAHs
released to water from the sediments would be readily volatile and the potential exposure
duration of the test animals in the test chambers would be greatly decreased by this
aeration. Sediment oxygen demand, a necessary piece of information to more fully
evaluate this situation, was missing from the report.
The results from the laboratory toxicity testing would have been more convincing
if the tests had been conducted as static tests or as static renewal tests using water
collected from the site without aeration (Appendix B, p.2). Further, the researchers
amended sediments (producing positive controls with known or anticipated toxicity) that
would have convinced a reviewer that these tests as conducted have some ability to detect
toxic sediments. However, the results that were obtained (lack of toxicity of amended
sediments) were not explained. The fact that no toxicity was observed in some of the
reference toxicity tests in which we would expect to observe significant toxicity would
cause one to suspect these test results and certainly question their utility. Given the way
that these laboratory toxicity tests were conducted, complete mortality of benthic
biota in the reservoir could actually be occurring at these sites, and we would not
know.
I would not argue that the tests were not conducted according to "accepted"
protocols (e.g. ASTM, US EPA), but those protocols have sufficient flexibility to produce
results in the laboratory that will not accurately reflect the field situation or conditions.
For example, survival of 40-50% of test animals in some replicates was averaged in with
other replicates with greater survival without comment or other supporting data. Growth
of surviving midges was compared on an individual basis to controls in this report, rather
than comparison of aggregate growth giving a false sense of lack of effects (if you
survived your growth was not affected). The growth data contained in this report simply
indicate that if the midges (C. tentans) survived, they grew, not that there were no effects
on growth. There are no scientific data to support the notion offered by the authors of this
report: "This characterization of toxicity and bioavailability of PAHs in aquatic
sediments from Badin Lake indicate that the PAHs present in the sediment samples do
not represent a significant source of toxicity to benthic aquatic organisms." Indeed, the
authors have provided data in their report indicating clear risks of adverse effects and that
a more thorough and careful evaluation should have been conducted. Total PAH 34
concentration at Station BL06 exceeded the NOAA sediment screening standard
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indicating the potential to cause adverse effects in situ. This situation could be better
resolved by sampling and measuring the benthic invertebrates from stations in the
reservoir and sorting through the factors that could contribute to false negative results in
the laboratory toxicity tests.
Due to the lack of toxicity measured in these tests and other confounding factors,
the second objective of this study could not be adequately addressed.
Review of RCRA Facility Investigation Report - Volume I of II and Volume II of II,
ALCOA Badin Works, Badin, NC (March 2001) by MFG, Inc., Pittsburgh, PA
Contaminants of interest in this study included cyanide (ground water and soil -
free cyanide and Fe cyanide complexes, hexacyanoferrate complexes, ferro-ferric
cyanides), arsenic, benzo(a)anthracene, benzo(a)pyrene, benzo(a)fluoranthene,
dibenzo(a,h)anthracene, indeno(1,2,3-ed)pyrene, benzene and trichloroethylene.
Sediment data were collected from Badin Lake (p.100) and the analyte concentrations
were compared with industrial soil RBC's. Although this comparison was deemed
conservative, it is based on solely human contact. It is a common practice to also consider
potential ecological effects by initially comparing the analyte concentrations with
screening values for sediments (e.g. NOAA). Analyte concentrations in sediments such
as benzo(a)pyrene (a potent carcinogenic PAH) pose a probable risk for swimmers in
Badin Lake. Based upon the NOAA Sediment Screening values (used to indicate
potential adverse ecological effects), arsenic, PCBs, benzo(a)pyrene as well as several
other organic compounds exceeded concentrations indicating the need for additional
investigation (Table 4-58, 4-59). For example, concentrations of fluoranthene reported
(0.063-360 mg/kg ) exceed known toxic concentrations in sediments for benthic
invertebrates (e.g. Stewart and Thompson 1995).
Review of "Badin Lake Swim/Picnic Area and Badin Boat Access Sediment
Assessment, Stanly County, North Carolina" by Environmental Services, Inc.,
Raleigh, NC
This study was conducted by ESI to measure sediment concentrations of several
elements and compounds in Badin Lake associated with industrial activity. Seven stations
were selected in Badin Lake for study. Sediment samples were collected from the Badin
Lake Swim/Picnic Area and the Badin Boat Access site in Stanly County, North
Carolina. Four stations were located within the Badin Lake Swim/Picnic Area, and two
stations were located near the boat ramp in the Badin Boat Access site. One station was
located in a cove approximately 2.75 miles northeast of the other sampling stations and
was designated as a reference site. Based on the information provided in the Report,
sampling of sediments appeared to be appropriate with triplicate samples collected to
provide precision information. Equipment blanks were also collected prior to sampling
and after sampling, although these equipment blank data do not provide a significant
measure of accuracy contrary to the indication in the Report (p.4). The equipment blanks
simply indicate that the equipment was appropriately cleaned prior to collecting the
samples. The sediment samples were collected from the sediment surface (sediment-
13
water interface) using a petite ponar sampler. Sediment samples were homogenized at the
surface (in the boat) potentially resulting in the loss of volatile contaminants.
Sediment samples were analyzed for arsenic, barium, cadmium, chromium, iron,
lead, selenium, cyanide (amenable, total and weak acid dissociable), fluoride, mercury,
polychlorinated biphenyls (PCBs) (Aroclors 1242, 1248, 1254, and 1260), and
semivolatile organic compounds (SVOCs) (acenaphthene, acenaphthylene, anthracene,
benzo(a) anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene,
benzo(k)fluoranthene, chrysene, dibenzo(a,h)anthracene, fluoranthene, fluorine,
indene(1,2,3-cd)pyrene, naphthalene, phenanthrene and pyrene). Analytes were
apparently measured in sediments on a dry weight basis (based upon information in
Tablel of the Report).
Although limited, the results from this study indicate significant contamination in
the sediments at the Badin Lake Swim/Picnic Area and the Badin Boat Access site
relative to the reference site. Importantly, arsenic, PCBs (Arochlor 1242), and SVOCs
(benzo(b)fluoranthene and benzo(a)pyrene) were measured at concentrations that can
pose significant human health risks. Several analytes such as arsenic in sediments at the
study site exceeded concentrations that indicate potential for adverse ecological effects to
biota. Further, analytes (concentrations and distribution) such as fluoranthene and
anthracene indicate an ongoing source. The lack of detection of selenium in any sediment
sample is perplexing and troubling. Selenium is a common element found in sediments
and is essential for plant and animal life. Although selenium may be present at a
relatively low concentration, it should be detectable by any reasonably sensitive
analytical technique (e.g. ICP). The study authors recommend a more comprehensive
study.
Review of "Fish Sampling Work Plan - Narrows Reservoir, Badin, North Carolina"
by URS Corporation, Franklin, TN (December 14, 2007)
The stated purposes or objectives of this proposal for fish tissue "monitoring" are
to:
1) Determine if PCB and dioxin congeners detected in sediments in the Narrows
Cove have been released and subsequently have accumulated in fish collected
adjacent to the Narrows Cove;
2) Determine if PCB Aroclors are detected in fish tissue samples; and
3) Determine if the concentrations of PCB and dioxin congeners and PCB
Aroclors detected in fish tissue samples collected adjacent to the Narrows
Cove are comparable to background levels detected in tissues collected from
an upgradient area not influenced by the site.
The first part of this review relates to the fundamental design of the study and the
second part focuses on specific items contained or not contained in this proposal.
The concept underpinning the first objective is fundamentally flawed. PCB and
dioxin congeners vary widely in their fate properties. For example, the PCBs and dioxins
14
that are found in the sediments would likely differ significantly from those found in the
fish adjacent to those sediments. The PCB and dioxin congeners that mobilize from the
sediments and subsequently bioaccumulate in fish will be a function of the molecular
weight and degree chlorination of the bioavailable fraction of PCBs in the sediment and
incoming to the reservoir if there is an ongoing source. Further, this phenomenon will
not be uniform across the congeners. So, the objective to seek PCB and dioxin congeners
in the fish tissue that have been previously detected in the sediments will need very
careful analysis. It would not be unusual for chemicals in the sediments to differ
significantly from chemicals found in the fish. Fish may have been exposed for two to
three years while sediments likely have been in contact with these materials for decades.
Basically, one would not expect the fish to act like the sediments in accumulating PCBs
and other hydrophobic chemicals. The sediments will not "respond" to PCB or dioxin
congeners as fish will. To what sediment data will the analytes in the fish tissue be
compared? No synoptic analysis of sediments was included in this proposal. What levels
of analytes will be considered (> detection)? Is this a quest for a "fingerprint" or
detection? Or is this a question of human health or ecological condition? These are all
important and worthy objectives, but the actual objective being pursued in this study is
unclear.
The second objective, to determine concentrations of PCB Arochlors in fish
tissue, will permit a conclusion regarding the presence and amount of individual Aroclors
in fish filets. Based upon fundamental scientific principles and previous studies, these
results and conclusions will likely not link directly to environmental measurements
(sediment concentrations). If the PCBs in sediments originated from disposal of
electrical equipment from the site, they are likely not uniformly distributed. Numerous
sediment samples could have been collected and a field triage analysis performed using
immunoassay to screen the samples in the field. Then the study would produce a more
complete picture of the sediment PCB contamination (or lack of contamination).
As posited in the study proposal, the comparison of concentrations of analytes in
fish tissue from two sampling locations is intriguing, but the value of the proposed study
is questionable and diconcerting. Three possibilities can be anticipated: 1) no analytes are
detected in fish tissue from either sampling location, 2) relatively high levels of analytes
are found in fish tissue samples from both sampling sites, and 3) one site has higher
concentrations of analytes than are found the fish tissue from the other site. The results
from this sampling and analysis are not likely to be straight forward; instead, they will
likely be mixed and confounded. Regardless, what conclusion can possibly be drawn
from this sort of comparison? If the fish contain PCBs or dioxin congeners, where did
they come from and how do we fix it? If the fish do not contain PCBs or dioxin
congeners, why not? The purpose of this study is not clear. Is it related to human health
or intended to allay the concerns of fish consumers? Or is the study related to
environmental condition and the potential for adverse ecological effects? The study, as
presented or proposed, does not adequately or convincingly answer either question.
Other specific concerns with this proposal include: the authors state (p. 2-3) that
lipid analysis methods will be identified in Section 5, but I could not find the method in
15
section 5, or anywhere else in the proposal. Matrix "spikes" and internal standards are
crucial in these analyses. Are they proposed for all analytes? Why were filets selected for
analysis? Analysis of fish filets is of limited value for ecological risk assessment and will
like produce lower concentrations or numbers than analysis of whole fish. Will the data
be provided as concentrations of analytes or lipid normalized concentrations or both? The
selection and implementation of a lipid analysis method could strongly influence the
outcome of this study.
Badin Lake is over 5,000 acres. The study will have to be carefully designed to
obtain representative samples to provide any information of consequence to draw any
meaningful conclusions regarding human health or ecological risks. For example, it
would be important to retain and share split samples so results can be confirmed. This
report proposes to gather data on fish tissue burdens of analytes of concern (e.g. PCBs).
The study outlined in this report could benefit from explicit statement of objectives and
establishing a robust experimental design with analytical detection limits to address both
human health and ecological concerns.
Review of : Yadkin-Pee Dee River Basinwide Water Quality Plan (March 2003),
Yadkin-Pee Dee River Basin Basinwide Assessment Report Whole Effluent Toxicity
Program (2002-2006), Yadkin-Pee Dee River Basin Ambient Monitoring System
Report (2002-2006), Lake and Reservoir Assessments - Yadkin-Pee Dee River Basin
(2007) (NCDENR Reports)
Yadkin-Pee Dee River Basinwide Water Quality Plan (March 2003)
Information contained in this report indicates that the NC Department of
Environment and Natural Resources requires or utilizes extensive (essentially watershed
level) studies on instream flow and water quality in the relicensing process. Concerns
that were documented and require additional follow-up included the fish kills
experienced in Badin Lake and poor water quality conditions (particularly in 2000 and
2001). The fish kills identified involved striped bass, bream and catfish. The presence of
small sores and emaciation of some of these fish were reported. A study was initiated to
address these concerns by IDWQ. Nutrient enrichment was also cited in this report as a
concern (p.197). Food supply for predatory fish, elevated water temperatures and
dissolved oxygen were also of concern and indicated impairment of water quality. DWQ
committed to working with Yadkin Division of APGI to improve water quality in Badin
Lake during the hydropower relicensing process. No information was provided regarding
activities or accomplishments.
Yadkin-Pee Dee River Basin Basinwide Assessment Report Whole Effluent Toxicity
Program (2002-2006)
Alcoa has 5 NPDES permits into Badin Lake or Little Mountain Creek listed in
this report. Only 2 NPDES permit violations were reported during the period of this
16
report (2002 - 2006). The source and magnitude of those violations were not contained in
this report.
Yadkin-Pee Dee River Basin Ambient Monitoring System Report (2002-2006)
This report contains generic information about the watershed and emphasizes
numerous water quality concerns. These water quality concerns or exceedences of water
quality criteria can be readily connected to hydropower and dam operation as noted
above in this report. They include turbidity, metals, dissolved oxygen, pH and
chlorophyll a.
Lake and Reservoir Assessments - Yadkin-Pee Dee River Basin (2007)
This report noted that Badin Lake dissolved oxygen and pH values lake-wide that
were less than state water quality standards. This report also noted that water column
chlorophyll a values did not exceed the state water quality standard, but that benthic mats
were apparent. The noxious alga, Lyngbya wollei, was identified at several sites in Badin
Lake. Just as excessive growths of planktonic algae (i.e. chlorophyll a) can cause
significant disruption of water resource usages, so can blooms of benthic, mat-forming
algae, such as Lyngbya wollei. Lyngbya has caused problems ranging from eroding
property values, and production and release of taste-and-odor compounds, to avoidance
behavior by some fish species (Speziale and Dyck 1992; Doyle and Smart 1998; Mastin
et al. 2002; Cowell and Dawes 2004). Lyngbya produces several toxins that can adversely
affect human health as well as the health of organisms living in or depending on the
reservoir (Mastin et al. 2002). The filamentous cyanobacterium (blue-green alga),
Lyngbya, forms dense benthic and surface mats with cells protected by an external sheath
comprised of polysaccharides, peptidoglycans and minerals such as calcium carbonate
(Speziale et al. 1991; Speziale and Dyck 1992; Doyle and Smart 1998). Lyngbya can
thrive at extreme temperatures ranging from melt-water lakes and streams to hot springs
(Graham and Wilcox 2000). This alga also contains photosynthetic accessory pigments
(i.e. phycobilins) that permit growth in low light conditions (i.e. < 2% incident
photosynthetically active radiation). Lyngbya can grow in waters with low nitrogen
concentrations (< 0.07 mg N03-N / L) due to its ability to fix atmospheric nitrogen
(Cowell and Dawes 2004). Mats of L. wollei can achieve a biomass of 1.0-1.5 kg dry
weight/m2 (4047-6070 kg/acre) weight with - 40-100% of this biomass existing as
benthic mats (Beer et al. 1986; Speziale et al. 1988 and 1991; Cowell and Botts 1994;
Doyle and Smart 1998). Lyngbya is a sentinel species in that it indicates water quality
issues. Lyngbya can also clog water intakes and interfere with activities such as
hydropower production.
V. Summary and Recommendations (Professional Opinions)
1. The available data regarding environmental conditions and water quality in Badin
Lake, and the potential influence of dam or hydropower operations on that water,
sediment and biota, are limited. However, the data that are available clearly indicate that
Badin Lake and downstream areas have significant environmental problems (both human
17
health and ecological) that are and will continue to be affected by dam operations and
should in any event be addressed in the Section 401 certification process.
2. Data provided by Alcoa and its consultants, as well as data collected by
consultants for Stanly County, clearly indicate an ongoing source of contaminants in
Badin Lake and release of contaminants downstream that should be investigated further.
3. Due to the paucity of data available and the nature of those data, it is not possible
at this time to accurately gauge the extent and magnitude of the problem(s) in Badin Lake
or in the downstream area. Strategic, well designed studies need to be conducted so these
water resources can achieve the designated uses that are impaired by water quality.
4. Careful, well-designed and comprehensive studies should be executed, initially to
determine the nature, extent and magnitude of the problem(s) in Badin Lake and the
immediate watershed (as well as the downstream area). At present, it is clear that there
are problems (e.g. Lyngbya wollei, toxic materials) that are affected by and could be
exacerbated by dam or hydropower operations. However, this situation is more complex
than a single consideration, and the ramifications of dam or hydropower operations on the
environmental conditions in the reservoir need to be fully considered. Decisions
regarding water quality and impacts of dam or hydropower operations need to be the
carefully considered and informed decisions that the Clean Water Act requires.
5. Clearly, the Section 401 certification decision has not considered these concerns
and problems.
18
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