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HomeMy WebLinkAbout20070812 Ver 1_Public Comments_20080502 (2645)PARKER POE ADAMS & BERNSTEIN LLP Thomas N. Griffin, III Partner Telephone: 704.335.9049 Direct Fax: 704.335.9567 tomgri ffin@parkerpoe. com Attorneys and Counselors at Law May 1, 2008 VIA FEDERAL EXPRESS and E-MAIL Mr. John Dorney 401 Development Unit Supervisor North Carolina Division of Water Quality Wetlands and Stormwater Branch 2321 Crabtree Boulevard Raleigh, North Carolina 27604 Three Wachovia Center Suite 3000 401 South Tryon Street Charlotte, NC 28202-1935 Telephone 704.372.9000 Fax 704.334.4706 www.parkerpoe.com ag, @ 9 M 9 U? MAY 2 2008 NR WATER QUAU? DE LANDS AND STORMWATER BRANCH V&T Re: Comments by Stanly County to Section 401 Water Quality Certification Alcoa Power Generating, Inc. FERC Relicensing Project No. P-2197-0000 DWQ Project Number 2007-0812 Dear Mr. Dorney: I represent Stanly County, North Carolina (the "County") with respect to matters arising out of the request by Alcoa Power Generating, Inc. ("APGI") for a water quality certification under Section 401 of the Federal Clean Water Act. As you know, APGI is seeking a new 50- year license from the Federal Energy Regulatory Commission ("FERC") to operate its Yadkin Hydropower Project (FERC No. P-2197) located on the Yadkin River in North Carolina (the "Project"). The Project includes the Narrows Dam (the "Dam") on Badin Lake. The Lake, in turn, is a significant, 5,300-acre water body located along Stanly County's northeastern boundary that serves as a primary drinking water source and is one of the best fishing and swimming lakes in North Carolina. The County is vitally interested in the Lake's condition, and is writing to urge the Division of Water Quality ("DWQ") either to deny APGI's request for a Section 401 certification or ensure that any such certification adequately addresses documented water quality issues. This is DWQ's second consideration of APGI's application for a Section 401 certification. The County challenged the first certification (issued on November 16, 2007) through a contested case proceeding, believing strongly that DWQ did not properly identify and consider water quality concerns and/or impacts that will arise from hydropower operations. During that contested case, the evidence confirmed that the County's fears were well-founded. We are now writing to highlight that evidence, express our dismay at DWQ's view of its jurisdiction and present you with an expert report (from one of the country's best known water quality experts) demonstrating that there are serious water quality issues in Badin Lake that fall CHARLESTON, SC COLUMBIA, SC MYRTLE BEACH, SC RALEIGH, NC SPARTANBURG,SC PPAB 1426636v2 Mr. John Dorney May 1, 2008 Page 2 directly within your Section 401 jurisdiction, no matter how it is defined. We ask that DWQ review the available information carefully and exercise its power to protect Badin Lake and its users. DWQ Has Voluntarily and Inappropriately Limited its Own Section 401 Jurisdiction to the Point Where It Cannot Adequately Protect Water Quality as Mandated by the Clean Water Act We have previously provided you with you a detailed letter, dated November 9, 2007, which described several water quality issues impacting the Lake. To place those issues officially in the "record" for this second consideration of APGI's application, I have enclosed another copy of the County's earlier letter. The issues in that letter related primarily to the presence of significantly contaminated sediments at several locations in the Lake, and we described how those conditions would directly impact water quality within your jurisdiction. The contamination, in turn, was documented in several reports from different sources and consultants. We were surprised and disappointed to learn in the contested case that these conditions were not evaluated and that DWQ did not read the reports that we brought to its attention. We were just as surprised to learn that DWQ does not intend to read the reports, inquire further of APGI or otherwise evaluate the issues that we raised. We are at a loss to understand how DWQ, whose primary mission is the protection of the water quality of this State, can take such a limited view of its responsibilities that it will not consider the matters in our previous comments in any material way. I raise the issue of DWQ's responsibility because we apparently have diametrically opposed views of Section 401 jurisdiction. In DWQ's view, a clear, detrimental water quality condition can exist in the Lake and DWQ will not attempt to address it under the Section 401 program unless we can demonstrate that the actual operation of the Dam affects that condition in some fashion. Thus, the presence of confirmed, severe levels of polyaromatic hydrocarbons in Lake sediments cannot even be considered in the Section 401 review because they were not initially caused by Dam operations and/or we did not show DWQ by expert evidence that Dam operations would cause those sediments to impact water quality. We submit that this view is inappropriate for two primary reasons, among others.' First, as you have acknowledged, the concept of "water quality" is quite broad, and encompasses many factors beyond "just" numerical levels. In Badin Lake, these factors include fishing, recreation, biological integrity and several other aspects of the "best usage" of the water. Certainly, conditions such as those that we highlighted can impact these factors directly; you stated as much in your recent testimony. ' In the second part of this letter, we present an expert report demonstrating that DWQ was wrong in its refusal to consider the conditions presented by the County. Even under DWQ's limited view of Section 401 jurisdiction, the conditions presented by Stanly County, as well as numerous other serious water quality concerns, are indeed present in the Lake and affected by Dam operations, and therefore should be considered as part of the Section 401 review. PPAB 1426636v2 Mr. John Dorney May 1, 2008 Page 3 Second, and importantly, DWQ can and should extend its Section 401 jurisdiction to all water quality issues that exist in the Lake and that relate in any reasonable fashion to the presence of the Project, including the impoundment of water by the Project's dams, the operation of the dams, stream flows, water levels, the use of the Lake for recreation and the like. The broad reach of DWQ's jurisdiction was confirmed by the United States Supreme Court in PUD No. 1 of Jefferson Count v. Washington Dep't of Ecology, 511 U.S. 700 (1994). In PUD, the applicant for a FERC license argued, as does APGI in this case, that a Section 401 certification can consider only those impacts related to an actual discharge from a dam/project (the discharge from the end of a tailrace, in that case). The Supreme Court explicitly rejected this limited view, holding instead that: Section 401(d) thus allows the State to impose "other limitations" on the project in general to assure compliance with various provisions of the Clean Water Act and with "any other appropriate requirement of State law." ... Section 401(d) is most reasonably read as authorizing additional conditions and limitations on the activity as a whole once the threshold condition, the existence of a discharge, is satisfied. Id. at 711-12 (emphasis added). The petitioner in PUD also argued that the State could not force it to operate its dam in a manner consistent with a designated "use," but the Supreme Court rejected that position, as well. The Court in fact confirmed that a state can impose, for example, minimum flow requirements to protect uses such as drinking water, recreation, navigation or, in that case, a fishery. Id. at 719. Through its decision in PUD, the Supreme Court has confirmed that DWQ should not limit its review to only those conditions actually caused or somehow affected by the operation of the Dam itself. The Section 401 process is DWQ's chance to impose conditions on the "project in general" and "the activity as a whole" to ensure that State law is being met, including the State law related to the protection of best uses of the Lake. Certainly the Lake itself, which would not exist but for the Dam, is part of the "project in general," whether or not APGI operates the Dam in any particular fashion. Certainly, as well, under this broad authority DWQ may recognize that contaminated sediments are present, and then require that APGI address them so that the "activity as a whole" meets water quality standards. Again, DWQ appears to have recognized that the issues raised by the County do indeed constitute adverse impacts to water quality. Now is the opportunity for DWQ to require investigations and impose conditions necessary to ensure that those water quality impacts are addressed and that the best uses of the Lake are protected. DWQ's authority to view the "project in general" is very broad in a FERC context precisely because the rights and powers conferred by FERC on APGI are so comprehensive. As I understand it, the FERC license empowers (and in fact requires) APGI to control the entire lake PPAB 1426636x2 Mr. John Dorney May 1, 2008 Page 4 system, including uses of the Lake and the control of the waterways. The "activity as a whole" therefore must necessarily include the same kinds of uses that are included in North Carolina's water quality standards, such as recreation, fishing and the like. In other words, once the "discharge" from the Dam invokes Section 401 jurisdiction, DWQ may legitimately impose appropriate conditions on all aspects of APGI's activities authorized by the FERC license, including the maintenance of the Lake. See PUD, 511 U.S. at 724-25; S.D. Warren Co. v. Maine Bd. of Envt'1 Protection, 126 S.Ct. 1833, 1848 (2006) (holding that a discharge from a dam is a "discharge" that meets the threshold requirement for Section 401 jurisdiction). DWQ's failure to do so is a missed opportunity to protect the State's interests before APGI receives a new 50-year FERC license. Moreover, as we discussed, beyond DWQ's authority to impose conditions in a Section 401 certification (which must then be accepted by FERC), there are not likely any other State agencies who can impose dam and lake system operating conditions on APGI as a FERC licensee. So if DWQ chooses not to protect the Lake, then who will? Who will ensure that the Lake is operated over the next 50 years in a fashion to protect water quality? If DWQ elects to unnecessarily restrict its jurisdiction under Section 401, the State will essentially abdicate its independent role as the arbiter of water quality matters in a FERC project and leave North Carolina's citizens unprotected. This is just as effective a "waiver" of the State's authority as letting the one-year period in Section 401(a) expire. We urge DWQ not to take this restrictive position. DWQ's self-limitation is not mitigated by the agency's participation in the Relicensing Settlement Agreement ("RSA") process. First, as a practical matter, the RSA negotiations are just that - negotiations. They seek compromises and tradeoffs that may or may not represent the best conditions that could reasonably be imposed to protect water quality. DWQ cannot know whether this is the case in the APGI application because, except for very limited circumstances, DWQ apparently did not independently evaluate the RSA conditions that were adopted wholesale into the Section 401 certification.2 It seems that DWQ did not take full advantage of the reservation of its rights in the final RSA document.3 Second, and more importantly, the next 2 The danger of relying on the RSA materials without independent review in the Section 401 process is highlighted by the report entitled Normandeau and Associates, Inc., Yadkin Project, FERC No. 2197 NC, Yadkin Water Quality Monitoring Report, Final Study Report (2005). In that report, the consultant apparently selected detection limits for its tests that exceeded the state water quality standards. It would be possible, therefore, for constituents to exist in the water above the state standard but below the chosen detection limit, and the test would still give the water a clean bill of health because the results would be "non-detect." These analyses cannot be relied upon to conclude that water quality standards were met, and DWQ should have required lower detection limits or further analyses. 3 The RSA is arguably somewhat confusing on Section 401 jurisdiction. It states clearly that the State retains its Section 401 jurisdiction, but also imposes obligations on its signatories (including DENR) to not challenge substantive matters in the Section 401 process. The RSA also states that "[e]xecution of this Settlement Agreement by the State of North Carolina or any agency thereof expresses or implies no representation that the requirements of this Settlement Agreement ensure compliance with State water quality standards and other appropriate requirements PPAB 1426636v2 Mr. John Dorney May 1, 2008 Page 5 section of this letter demonstrates that there are numerous, serious water quality concerns that were not addressed in either the RSA or the Section 401 process. By relying almost entirely on the RSA and not evaluating its own materials and research concerning the Lake, DWQ is exercising its authority without an independent basis for knowing whether it has adequately protected the citizens of the State concerning the quality of the waters at issue; furthermore, DWQ is truly missing a seldom available opportunity to improve and protect water quality. Finally, we question DWQ's internal process, applied here, in apparently deciding to programmatically limit its Section 401 jurisdiction in all FERC projects. As we understand the situation, DWQ decided that, in FERC projects, it would not consider water quality issues that derived from "watershed effects" unless those effects could be hurt or helped in some fashion by operating the dam at issue. This decision was made internally by DENR personnel, was not subject to rulemaking or guidance and was apparently not based on any legal opinion or interpretations. Concerning the Project, it seems that DWQ decided that some conditions that derive from or relate to the "watershed" (such as the sedimentation issues raised by the City of Salisbury or the shoreline management plan) were subject to Section 401, while others (such as the presence of contaminated sediments or the potential for impacted fish populations) were not. In the latter case, it appears that DWQ conducted no truly material analysis or review, even of the basic data, in reaching its conclusion. We submit that DWQ's jurisdictional decision is inappropriate for at least two reasons. First, (on a project-specific basis) absent some level of evaluation, and absent some level of guidance or rulemaking, DWQ's decisions with regard to "watershed effects" can only be ad hoc and arbitrary. They certainly appeared to be so in this case. Second (from a State's interest standpoint), "watershed effects" (however this term is defined) can be notoriously difficult to control in any uniform manner, and can take years before any improvement is noticed in the receiving water bodies. During that time, the water body remains impacted and water quality can deteriorate. In a FERC context, the Section 401 certification offers DWQ a real chance to improve water quality by imposing conditions on "the project in general" that implement "appropriate requirements of State law," including among other things the best usage and biological integrity of the State's waters. We ask that DWQ invoke the full extent of its jurisdiction under Section 401, review all water quality conditions in the Lake through the Section 401 certification and avoid the line-drawing and arbitrariness that inevitably derives from proceeding in the absence of formal rules or guidance and leaves the public unaware and unprotected. of State law." In the contested case, however, we learned that, for the most part, DWQ did indeed simply adopt RSA provisions wholesale for the Section 401 certification and did not conduct truly substantive independent analysis of the appropriateness of many of the balances struck in the settlement negotiations. PPAB 1426636v2 Mr. John Dorney May 1, 2008 Page 6 Serious Water Quality Issues In the Lake Are Raised By DWQ's Own Investigations, Reports Generated In The RSA Process And In The Reports Referenced By Stanly County, Yet None Of Them Were Considered by DWQ Since the County's original comments, it has become clear that the contaminated sediments noted by the County are but one of numerous water quality issues in Badin Lake. It has also become clear that these issues were identified by DWQ itself, and were studied to some extent in the RSA process. Finally, there is no doubt that the conditions are either created by Dam operations or are affected by those operations. Given these conditions, we believe that DWQ must require through the Section 401 certification that APGI take action to improve these water quality issues and protect the Lake. To assist the County in presenting the specific water quality issues in the Lake, we retained Dr. John Rodgers of Clemson University. Dr. Rodgers is a renowned expert on precisely the matters now before DWQ, and his enclosed 67-page curriculum vitae details his vast knowledge of water quality matters. He is particularly knowledgeable on water quality issues resulting from or related to hydropower dam operations, and currently advises clients and state governments on such matters (including Section 401 issues). Dr. Rodgers reviewed several reports related to water quality issues in the Lake, including many authored by DWQ itself, and prepared a report for your review. I have enclosed a copy of his report with this letter. The report is comprehensive and speaks for itself. In brief, Dr. Rodgers concludes that testing and evaluation over the past several years, including during the RSA process, revealed numerous issues, and he highlights the "top ten" that he discovered. These include sediment release and transport impacting ecological resources, the presence of lyngbya wollei (an invasive and toxic algal species), releases of suspended solids, poor dissolved oxygen profiles, releases of toxic elements, the impact of Dam operations on eutrophying nutrients, bioconcentration and other effects of toxic compounds in downstream biota, general water quality for spawning and support of aquatic life, the impact of strong seasonal stratification in the Lake and water quality issues coupled with drought planning. Even with this many serious items, Dr. Rodgers was careful to note that his list of water quality concerns is not exhaustive. Clearly there are issues in the Lake that DWQ did not, but should, address in its review of APGI's Section 401 certification application. Importantly, Dr. Rodgers also highlights how Dam operations can and do affect the water quality issues that he has highlighted, and he cites numerous scholarly references to substantiate his conclusions. He notes, for example, that fined-grained sediments can readily be transported in river systems, including those with dams, and that "movement of contaminants downstream from a reservoir through dam operations is common." He points out, among other things, that contaminants may be mobilized and transported so as to pose risks to humans and downstream biota, that sediments can become suspended in the water body, that redox conditions in the reservoir can lead to the release of certain elements and contaminants and that water releases PPAB 1426636v2 Mr. John Dorney May 1, 2008 Page 7 from the Dam are important in controlling adverse water quality conditions that are present in and downstream of the Dam.4 He also highlights that there are practical ways to address some of these issues such as, again, by regulating water levels and releases. Clearly, additional review and consideration is warranted, but for now Dr. Rodgers concludes his review of water quality conditions by noting that the Dam's operations can adversely impact water quality and exacerbate existing conditions, and through proper regulation, may help to avoid and solve problems. Therefore, even using DWQ's restricted view of its Section 401 jurisdiction, all of these conditions fall squarely within your purview and should be evaluated and addressed in the Section 401 process. It appears that these problems were nevertheless not addressed in any substantive way in the former Section 401 certification. We therefore do not believe that DWQ can or should reissue the certification on its previous terms. Importantly, we also believe that the certification must be revisited for even those conditions that were putatively addressed in the former Section 401 certification. The dissolved oxygen issues provide a prime example. DWQ acknowledged in the contested case that discharges from the Dam are now violating and will continue to violate water quality standards for dissolved oxygen. While the past Section 401 certification included a timeline for equipment upgrades, those upgrades extend years into the future and are not certain to bring the discharges into compliance. Based on the current information that we have, it also seems that DWQ did not consider other options, such as regulating water releases or implementing other techniques to address dissolved oxygen or the effects of low dissolved oxygen discharges. In the meantime, while we wait for future equipment upgrades, the water quality in the Lake will continue to be degraded and harm will come to the environment. While we understand that DWQ balances these considerations and decides whether they can be mitigated, where such obvious adverse effects go untreated for potentially years, we submit that the Dam activity will continue to degrade the existing uses of the Lake and waterway. In this circumstance, DWQ's regulations dictate that the Section 401 certification should not be granted. 15A NCAC 02H .0506. Dissolved oxygen is just one of the many serious issues identified by Dr. Rodgers that are currently resulting from Dam operations. If DWQ disagrees with this logic and issues a Section 401 certification despite the degradation of water quality resulting from the Dam's operation, the agency must still impose conditions to address the matters noted by Dr. Rodgers. In turn, to properly understand those conditions and how they can be mitigated or affected by Dam operations, DWQ must undertake further detailed evaluation of these matters. At the very least, DWQ should review the reports that the County identified and coordinate with the State's own experts to determine how best to proceed. In the contested case, DWQ described its process for evaluation of water quality impacts as screening for initial impacts and then further investigating the nature and extent of the issues. We agree with this approach, and ask that you implement it here. 4 In addition, Normandeau and Associates noted that sediment fate and transport can be affected by Dam operations. See Sediment Fate and Transport Report (Draft) by Normandeau Associates, Inc. and PB Power (December 2004). PPAB 1426636v2 Mr. John Dorney May 1, 2008 Page 8 Reports for Review To assist DWQ in its review, we have included with these comments a number of reports highlighting water quality impacts. For certain DWQ reports, in lieu of copies we have included the website address where they can be accessed and downloaded. The reports are: 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), available at http://h2o.enr.state.nc.us/basinwide/yadkin/YadkinPD wq_dt management plan0103.ht in. 4. Yadkin-Pee Dee River Basin Basinwide Assessment Report Whole Effluent Toxicity Program (2002-2006) (NCDENR Report), available at http://h2o.enr.state.nc.us/esb/Basinwide/YadkinWET2007.pdf. 5. Yadkin-Pee Dee River Basin Ambient Monitoring System Report (2002-2006) (NCDENR Report), available at http://h2o.enr. state.nc.us/esb/Basinwide/Yadkin07AMSRFinaIJune26.pdf. 6. Lake and Reservoir Assessments - Yadkin-Pee Dee River Basin (2007) (NCDENR Report), available at http://h2o.enr.state.nc.us/esb/Basinwide/YadkinLakes2006v7.pdf. 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) 10. Wetland and Riparian Habitat Assessment (Draft) by Normandeau Associates, Inc. (February 2005) PPAB 1426636v2 Mr. John Dorney May 1, 2008 Page 9 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) Please review all of these materials carefully in your analysis of this matter. In addition to the materials highlighted in our November 9, 2007 letter, we would suggest in particular that DWQ review the 2005 Water Quality Monitoring Report by Normandeau and Associates, the 2004 Draft Sediment Fate and Transport Report also by Normandeau (we have only a draft of this report) and DWQ's own 2007 report entitled Lake and Reservoir Assessments-Yadkin-Pee PPAB 1426636v2 Mr. John Dorney May 1, 2008 Page 10 Dee River Basin (April 2007).5 There are perhaps other reports that are or could be available concerning matters important to DWQ's consideration of APGI's application, but the listed materials provide a sufficient basis to conclude that the DWQ Section 401 program, in its important role of protecting the State's waters, needs to perform its own, additional evaluation to understand APGI's application. This work needs to extend beyond the understandings already developed in the RSA process; the RSA addressed certain conditions, but did not result in adequate solutions for the water quality issues in the Lake. Conclusion We have seen various references stating that the County challenged the former Section 401 certification because it did not have time to comment during the prior comment period. We have also seen references to the County's challenge as being a proxy for addressing issues related to the former Alcoa Badin Works facility in Badin, North Carolina. Neither of these is the case. As you know, the County believes firmly that important water quality information was not properly considered by DWQ, that the agency should have taken additional time to review that information and that, by not doing so, the agency issued an inappropriate certification that does not truly protect the Lake, which is an important County resource. Now, as the County has become aware of additional water quality information and received expert advice on the Lake, we are more convinced than ever that the Section 401 certification process is vitally important, and that it represents a critical (and perhaps the only) opportunity for DWQ to impose conditions and take steps to protect and improve the waterway. DWQ has stated that it could rely on the reopener provisions in the Section 401 certification to adequately protect water quality as issues arise in the future. We strongly believe that (i) DWQ should not rely on the reopener clause, because the water quality concerns are apparent now and should be addressed now, and (ii) while we acknowledge that FERC must include the reopener clause as a condition of a new FERC license, whether and how that reopener would actually operate or be honored in the future is an open question. Certainly DWQ has no experience with FERC on these matters, and we are not aware of cases that would provide DWQ with material guidance. Again, we submit that DWQ should not risk water quality and instead should evaluate the current conditions to make an appropriate Section 401 decision now, not in the future. Finally, we understand that DWQ may be concerned that it should rush to reissue a certification by May 9, 2008 to avoid an argument that it has waived its right to issue a Section 401 certification within the one-year period prescribed by Section 401(a), 33 U.S.C. § 1341(a). We agree that DWQ should not allow the certification to be waived. Under the applicable facts 5 Interestingly, the 2007 DWQ Lake and Reservoir Assessment Report noted the presence of lyngbya wollei in Badin Lake, while the 2005 Normandeau report on invasive species did not. This suggests that water quality decreased over those two years as conditions in the Lake become more hospitable to toxic algae. PPAB 1426636v2 Mr. John Dorney May 1, 2008 Page 11 here, we believe that DWQ is obliged to deny the certification as unsupported by APGI's current application and available information and materials, and to require that APGI resubmit an appropriate application that properly presents and addresses all the water quality problems present in Badin Lake. There is ample information demonstrating that the current and ongoing operation of the Dam does and will violate water quality standards, and as yet there is insufficient evidence or information that the Dam operations can be performed in such a way as to mitigate and remedy those violations. DWQ's rules thus support, and indeed require, that the application be denied at this time. Having denied the application, DWQ will have "acted" within the statutory timeframe, and preserved its right to receive a new application from APGI and, if warranted, to eventually issue a timely certification that FERC would be required to incorporate in a new license for the Project. This approach is both supported by the overwhelming evidence of water quality issues and serves the State's interests in having an enforceable voice in the FERC proceedings. We ask that you consider these comments and enclosed materials carefully, and that you deny the issuance of a Section 401 certification until these water quality issues are resolved. Thank you for the opportunity to comment on APGI's Section 401 application. Please do not hesitate to contact me if you should have any questions about the County's position. Very truly yours, a."-- Thom.'a1r. Griffin, III TNG:cmh Enclosures cc: Donald W. Laton, Esq. (w/Enclosures) (via Federal Express and E-Mail) David R. Poe, Esq. (w/Enclosures) (via Federal Express and E-Mail) Craig A. Bromby, Esq. (w/Enclosures) (via Federal Express and E-Mail) Charles D. Case, Esq. (w/Enclosures) (via Federal Express and E-Mail) PPAB 1426636v2 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 2 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 2 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). II. 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) 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. Significant 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 4 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 11 and Volume II of lI, 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 BBC'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. NOAA). 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. 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 7 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). 8 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 9 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. 10 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 12 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 "Kadin 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 Table 1 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. 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Falconer, I. R. 1993. Algal toxins in seafood and drinking water. London San Diego, CA: Academic Press. Fitzgerald, GP and DF Jackson. 1979. Comparative algaecide evaluations using laboratory and field algae. JAPM. 17:66-71. Fleming, L. E., Rivero, C., Burns, J. W., Williams, C., Bean, J. A., Shea, K. A., et al. 2002. Blue green algal (cyanobacterial) toxins, surface drinking water, and liver cancer in Florida. Harmful Algae, 1, 157-168. Fleming, L. E., & Stephan, W. 2001. Blue green Algae: Their toxins and public health issues. Miami, FL: NIEHS Marine and Freshwater Biomedical Sciences Centero. Document Number) Fujiki, H., Mori, M., Nakayasu, M., Terada, M., Sugimura, T., & Moore, R. E. 1981. Indole alkaloids: Dihydroteleociding B, teleocidin, and lyngbyatoxin A as members of a new class of tumor promoters. Proceedings of the National Academy of Sciences USA, 78(6), 3872-3876. Ghosh, RS, DV Nakles, IP Murarku and EF Neuhauser. 2004. Cyanide speciation in soil and groundwater at manufactured gas plant (MGP) sites. Environmental Engineering Science 21: 752-767. Graham L.E. and L.W. Wilcox. 2000. Algae. Prentice Hall. Upper Saddle River. NJ. Grauer, F. H., & Arnold, H. L., Jr. 1961. Seaweed dermatitis. First report of a dermatitis- producing marine alga. Arch Dermatol, 84, 720-732. Haughey, MA, MA Anderson, RD Whitney, WD Taylor, and RF Losee. 2000. Forms and fate of Cu in a source drinking reservoir following CuSO4 treatment. Water Research. 34(13):3440-3452. Hunter, P. R. 1998. Cyanobacterial toxins and human health. Symp Ser Soc Appl Microbiol, 27, 35S-40S. Jackim, E., and Gentile, J. 1968. Toxins of a blue-green alga: similarity to saxitoxin. Science, 162(856), 915-916. Kozikowski, A. P., Shum, P. W., Basu, A., & Lazo, J. S. 1991. Synthesis of structural analogues of lyngbyatoxin a and their evaluation as activators of protein kinase c. Medical Chemistry, 34(8), 2420-2430. 21 Martin Dean F, Barbara B Martin, Elsie D Gross, and Karen Brown. 1994. An annotated bibliography of Lyngbya. Biological Sciences. 57(3): 75-87. Mastin, B.J., J.H. Rodgers, Jr. and T.L. Deardorff. 2002. Risk evaluation of cyanobacteria-dominated algal blooms in a North Louisiana reservoir. JAquat Ecosyst Stress Recov. 9: 103-114. Moore, R. E. 1981. Toxins from marine blue-green algae. In W. W. Carmichael (Ed.), The Water Environment: Algal Toxins and Health. New York: Plenum Press. Moore, R. E. 1977. Toxins from blue-green algae. BioScience, 27(12), 797-802. Murray-Gulde, C. L., Heatley, J. E., Schwartzman, A. L., & Rodgers, J. H., Jr. (2002). Algicidal effectiveness of Clearigate, Cutrine-Plus, and copper sulfate and margins of safety associated with their use. Arch Environ Contam Toxicol, 43(1), 19-27. Mynderse, J. S., Moore, R. E., Kashiwagi, M., & Norton, T. R. 1977. Antileukemia activity in the Osillatoriaceae: isolation of Debromoaplysiatoxin from Lyngbya. Science, 196(4289), 538-540. Normandeau and Associates, Inc. 2005a. Yadkin Project, FERC No. 2197 NC, Wetland and Riparian Habitat Assessment Final Study Report (2005). Prepared for ALCOA Power Generating Inc., Yadkin Division, 293 NC 740 Highway, Badin, NC 28009-0576. Normandeau and Associates, Inc. 2005b. Yadkin Project, FERC No. 2197 NC, Yadkin Water Quality Monitoring Report, Final Study Report (2005). Prepared for ALCOA Power Generating Inc., Yadkin Division, 293 NC 740 Highway, Badin, NC 28009-0576. Osborne, N. J., Webb, P. M., & Shaw, G. R. 2001. The toxins of Lyngbya majuscula and their human and ecological health effects. Environ Int, 27(5), 381-392. Owens, P.N., R.J. Batalla,A.J. Collins, B. Gomez, D.M. Hicks, A.J. Horowitz, G.M. Kendolph, M. Marden, M.J. Page, D.H. Peacock, E.L. Pettigrew, W. Solomons, and N.A. Trustrum. 2005. Fine-grained sediment in river systems: environmental significance and management issues. River Research and Applications 21: 693-717. Ressom, R., San Soong, F., Fitzgerald, G., Turczynowicz, L., El Saadi, O., Roder, D., et al. 2000. Health effects of toxic cyanobacteria (blue green algae). Retrieved. from http://www. nhmrc. gov.au/publications/synopses/withdrawn/eh l 4.pdf. Shilo, M. 1967. Formation and mode of action of algal toxins. Bacteriol Rev, 31(3), 180- 193. 22 Snell T.W. 1980. Blue-green algae and selection in rotifer populations. Oceologia, 46(3), 1432-1939. Speziale, B. J., and Dyck, L. A. 1992. Lyngbya infestations: comparative taxonomy of Lyngbya wollei Comb Nov (cyanobacteria). Phycology, 28(5), 693-706. Speziale, B. J., Turner, G., and Dyck, L. 1990. "Giant" blue-green alga. In V. N. Reinhold (Ed.), Natural Resource Management of Water and Land (pp. 161-168). New York. Speziale, B. J., Turner, G. E., and Dyck, L. A. 1991. Physiological characteristics of vertically-stratified Lyngbya wollei mats. Lake and Reservoir Management, 7(1), 107- 114. Stafford, R. G., Mehta, M., and Kemppainen, B. W. 1992. Comparison of the partition coefficient and skin penetration of a marine algal toxin (lyngbyatoxin A). Food Chem Toxicol, 30(9), 795-801. Stewart, K.M. and R.S. Thompson 1995. Flouranthene as a model toxicant in sediment studies with Chironomus riparius. Journal of Aquatic Ecosystem Stress and Recovery 4: 231-238. Suedel, B.C. and J.H. Rodgers, Jr. 1991. Variability of bottom sediment characteristics of the continental United States, Wat. Res. Bull. 27:101-109. Suedel, B.C., J.H. Rodgers, Jr. and P.A. Clifford. 1993. Bioavailability of Fluoranthene in Freshwater Sediment Toxicity Tests. Environ. Toxicol. Chem. 12:155-165. Suedel, B.C. and J.H. Rodgers, Jr. 1996. Toxicity of Fluoranthene to Daphnia magna, Hyalella azteca, Chironomus tentans and Stylaria lacustris in Water-Only and Whole Sediment Exposures. Bull. Environ. Contain. Toxicol. 57:132-138. US Environmental Protection Agency. 1999. Aquatic Life Ambient Water Quality Criteria for Ammonia Update Fact Sheet (Internet access) 2008. US Environmental Protection Agency. 2008. Technical Fact Sheet on Polycyclic Aromatic Hydrocarbons (PAHs). Ground water and drinking water. (Internet access) 2008. Wang, F, RR Goulet and PM Chapman. 2004. Testing sediment biological effects with the freshwater amphipod Hyalella azteca: the gap between laboratory and nature. Chemosphere 37: 1713-1724. Yin, Q., Carmichael, W. W., and Evans, W. R. 1997. Factors influencing growth and toxin production by cultures of the freshwater cyanobacterium Lyngbya wollei Farlow ex Gomont. Journal of Applied Phycology, 9, 55-63. 23 November 9, 2007 Comment Letter from Stanly County, North Carolina to DWQ Re: AGPI's Request for a Section 401 Water Quality Certification PARKER POE ADAMS & BERN5PEIN LLP Thomas N. Griffin, III Partner Telephone: 704.335.9049 Direct Fax: 704.335.9567 Lomgriffin@parkerp oe. com Atiornrys and Counselors at Law November 9, 2007 VIA EMAIL AND CERTIFIED MAIL Mr. John Dorney 401 Development Unit Supervisor North Carolina Department of Environment and Natural Resources Division of Water Quality Mail Service Center 1650 Raleigh, North Carolina 27699-1650 john,dorney@ncmail.net Three Wachovia Center Suite 3000 401 South Tryon Street Charlotte, NC 28202-1935 Telephone 704.372.9000 Fax 704.334.4706 www.parkerpoe.com Re: Comments by Stanly County to Section 401 Water Quality Certification Alcoa Power Generating, Inc. FERC Relicensing Project No. P-2197-0000 Dear Mr. Dorney: Thank you for allowing Stanly County (the "County") the opportunity to submit comments on Alcoa Power Generating, Inc.'s ("APGI") request for a Section 401 water quality certification related to its Federal Energy Regulatory Commission ("FERC") relicensing application. For the reasons outlined below, the County strongly urges the Division of Water Quality ("DWQ") to take additional time (as permitted under the applicable rules) to gather and consider important environmental information related to the potential impact on water quality from APGI's proposed operation of the dam system. Among other things, critical information is now being gathered, and current data should be assimilated, to understand fully the potential impact that the proposed activities may have on Badin Lake (the "Lake") and related water bodies. The Lake is an approximately 5,000 acre lake that, as part of the Yadkin Pee Dee basin, serves as a primary drinking water source and is one of the best (and most frequently used) fishing and swimming lakes in North Carolina. The Lake is bordered by the former Alcoa Badin Works facility (the "Plant"), which conducted aluminum smelting operations from approximately 1915 until mid-2007, and both the Lake and the Plant are located in Stanly County. During the Plant's operations, wastes containing cyanide complexes and potentially other materials were disposed of at the Plant property. There is no doubt that historic operations at the Plant have contaminated the Plant property and have potentially impacted the Lake. See RCRA Facility Investigation Report ("RFI"), Alcoa Badin Works, Badin, North Carolina, CHARLESTON, SC COLUMBIA, SC MYRTLE BEACH, SC RALEIGH, NC SPARTANBURG,SC CLT 10851044 Mr. John Dorney November 9, 2007 Page 2 prepared by MFG, Inc. (March 2001). These comments focus on the extent to which DWQ has and should consider the potential that, in light of the current and historical environmental conditions, APGI's proposed operation of the dam and Lake system has impacted or may seriously impact water quality, including the biological integrity of the Lake. The Relicensing Application As you know, APGI, a wholly-owned subsidiary of Alcoa, Inc. ("Alcoa"), is in the process of relicensing its Yadkin Hydroelectric Project (FERC No. P-2197) located on the Yadkin River in North Carolina (the "Project"). APGI is seeking a renewal of its 1958 license for a 50-year term, the maximum time period permitted by law.1 As part of the FERC relicensing process, APGI applied for a Section 401 water quality certification from DWQ. Although we have not had an opportunity to review the information that APGI submitted to DWQ, the County believes that APGI has not provided DWQ with environmental information about how the Plant's operations may have affected the Lake. The County has attempted to assemble and supply such information to DENR's Solid Waste Division and has had several conversations with those officials regarding newly discovered waste sites. However, we are not aware that any of this information has been shared with DWQ for purposes of the 401 review. Accordingly, we believe that DWQ has not had the opportunity to evaluate how the continued operation of the dam system may affect or exacerbate any conditions, including whether any conditions would render the Lake in violation of the applicable water quality standards. For this reason, and the reasons presented below, the County respectfully requests that DWQ (i) extend its review of APGI's application pursuant to 15A N.C.A.C. 2H.0507(a)(5), and (ii) seek and evaluate additional information concerning the interaction of environmental conditions from the Plant and the operation of the Lake and dam systems prior to issuance of any water quality certification. When FERC issued Alcoa the original license in 1958, Alcoa employed over 900 local residents at the Plant and the electricity generated from the Lake was supposed to be used to power the smelting operations at the Plant. The situation now is decidedly different -- Alcoa announced the closure of the Plant on or about July 30, 2007, and by spring 2008, no local residents will be employed by the Plant and the Plant will not require any power to operate. Rather, Alcoa's request to renew its license is based purely on revenues from the sale of Project electricity (more than $40 million/year in gross revenues, according to Alcoa's estimates) derived from Alcoa's free use of the public's waters. The County submits that Alcoa's current relicensing proposal provides little or no benefit to the citizens of the State of North Carolina that would justify or offset adverse Project impacts to water quality. CLT 1085104v4 Mr. John Dorney November 9, 2007 Page 3 The Section 401 Certification Section 401 of the Clean Water Act (the "CWA") essentially requires that states issue a "Section 401 water quality certification" for all projects that may involve a discharge to waters of the United States and that require a Federal permit (including a FERC license). See 33 U.S.C. §1341(a). The Section 401 certification basically verifies that a given project will not degrade waters of the State or otherwise violate water quality standards. See id. Section 313 of the CWA, in turn, provides the states with authority to enact water quality standards. See 33 U.S.C. §1313(a). Finally, the North Carolina Environmental Management Commission has delegated to the Director of DWQ the authority to issue water quality certifications on behalf of the State of North Carolina. See 33 U.S.C. § 1341; N.C. Gen. Stat. § 143B-282(1)(u); 15A N.C.A.C. 02H. 0500. Factors To Be Considered In A Section 401 Certification Determination In evaluating a Section 401 certification, DWQ must first determine that the proposed activity does not remove or degrade the existing uses of the surface water and that water quality standards are met. 15A N.C.A.C. 2H .0506(a) and (b). Following this finding, DWQ must determine that the proposed activity: (1) has no practical alternative under the criteria outlined in [the rules]; (2) will minimize adverse impacts to the surface waters based on consideration of existing topography, vegetation, fish and wildlife resources, and hydrological conditions under the criteria outlined in [the rules]; (3) does not result in the degradation of groundwater or surface waters; (4) does not result in cumulative impacts, based upon past or reasonably anticipated future impacts, that cause or will cause a violation of downstream water quality standards through the use of on-site stormwater control measures; and (5) provides for replacement of existing uses through mitigation as described [in the rules]. See id, at 0506(b). In addition, DWQ's practice, appropriately, is to use the Section 404(b)(1) guidelines to assist it in evaluating the issuance of a Section 401 water quality certification for FERC licenses. See Internal DWQ Guidance, "Stream Mitigation for FERC-related 401 Certifications" (January 9, 2007); 33 U.S.C. §1344(b)(1). The United States Environmental Protection Agency ("EPA") issued such guidelines at 40 C.F.R. 230 et seq. The Section 404(b)(1) guidelines focus on, among other things, the avoidance and minimization of impacts to waters, and highlight the paramount importance of water quality CLT 1085104x4 Mr. John Dorney November 9, 2007 Page 4 standards. They state, for example, that no discharge of dredged or fill material shall be permitted if it "causes or contributes, after consideration of disposal site dilution and dispersion, to violations of any applicable state water quality standard." 40 CFR § 230.10(b)(1 ).z They also prohibit the proposed activity if it "cause[s] or contribute[s] to significant degradation of the waters of the United States." 40 CFR § 230.10(c). "[E]ffects contributing to significant degradation considered individually or collectively include: (1) [s]ignificantly adverse effects of the discharge of pollutants on human health or welfare, including but not limited to effects on municipal water supplies, plankton, fish, shellfish, wildlife, and special aquatic sites; (2) [s]ignificantly adverse effects of the discharge or pollutants on life stages of aquatic life and other wildlife dependent on aquatic ecosystems, including the transfer, concentration, and spread of pollutants or their byproducts outside of the disposal site through biological, physical, and chemicals processes.... " Id. The guidelines explain that the evaluation of the effects of each proposed activity must include, among other things, an analysis of: contaminant determinations (determination of the degree to which the material proposed for discharge will introduce, relocate, or increase contaminants) and aquatic ecosystem and organism determinations (determination of the nature and degree of the effect that the proposed discharge will have on the structure and function of the aquatic ecosystem and organisms). See 40 CFR § 230.11(d) and (e). For example, the impacts of the proposed activity on fish, crustaceans, mollusks and other aquatic organisms in the food web must be considered. See 40 CFR § 230.31(a). The regulatory authority must in particular consider whether the requested activity "affect[s] the populations of fish, crustaceans, mollusks and other food web organisms through the release of contaminants which adversely affect adults, juveniles, larvae, or eggs ...." Id. at § 230.31(b). The use of the Section 404(b)(1) guidelines as guidance, and their emphasis on potential biological/ecological impacts, also makes sense in light of North Carolina's own water quality standards. Badin Lake is classified as a Class WS-IV water with a Class B designation. Under North Carolina's water quality standards, the "best usage" of Class WS-IV waters 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." 15A N.C.A.C. 2B .0216(1). The "best usage" of Class C waters, in turn, provides that "[t]he waters shall be suitable for aquatic life propagation and maintenance of biological integrity ... [and] sources of water pollution which preclude any of these uses on either a short-term or long-term basis shall be considered to be violating a water quality standard." 15A N.C.A.C. 2B .0211(2) (emphasis added). Finally, "biological integrity" is "the ability of an aquatic ecosystem to support and maintain a balanced and indigenous community of z As you know, the guidelines focus on the discharge of dredged and fill material, which is governed by Section 404 of the CWA. However, their careful evaluation and explanation of how activities can affect aquatic systems, and their description of the important aspects of those systems, provides valuable guidance for understanding impacts to water quality in other circumstances, such as those presented here. CLT 1085104x4 Mr. John Dorney November 9, 2007 Page 5 organisms having species composition, diversity, population densities and functional organization similar to that of reference conditions." Id. at .0202(l 1)? We note that ecological factors are decidedly relevant in the evaluation of a request for a 401 certification. When imposing conditions on section 401 certificates, states may take into account a wide range of factors associated with the impact of a proposed use on water quality. Specifically, in S.D. Warren Co. v. Maine Bd. of Envt'l Prot., 126 S.Ct. 1843 (2006), the U.S. Supreme Court held that, in making 401 certifications, states may take into account the effect of a proposed use on the chemical composition of the surrounding water and its effect on a species' habitat or reproductive health and on recreational use. Id at 1853. The Court's reasoning was based in the idea that the impact of the changes caused by dams on water quality is a part of the business of states, and that the Clean Water Act's system is designed with those state concerns in mind. Id. Similarly, in PUD No. 1 of Jefferson County v. Washington Dep't of Ecology, 511 U.S. 700 (1994), the Supreme Court addressed the broad power of states in this context, noting that states may "place any conditions on a 401 certificate that are necessary to assure that the applicant will comply with effluent limitations, water quality standards.... and with `any other appropriate requirement of state law."' Id. at 712. There is no doubt, therefore, that DWQ should carefully review all environmental information that relates to potential impacts to biological integrity and ecosystems. For the APGI project, it is precisely this type of water quality information that DWQ must evaluate before it can issue a thoughtful decision on the proposed Section 401 certification. The 401 Certification Must Be Delayed To Provide Time For DENR To Evaluate New And Important Biolo;Qical And Water Quality Information The County's review of available information has revealed sources of existing environmental information that demonstrate the very real possibility that environmental conditions exist in the Lake system that may be affected by operation of the dams. That existing information is described in the next section of these comments. This section addresses critical information that is now being developed that should be considered in the Section 401 review. That information consists of a new study that will bear directly on whether and how environmental conditions could impact biological integrity, including important and sensitive species. The new study will be directly relevant to your decision-making process. Some consideration of the project's impacts on sensitive species is included in the April 22, 2007 Relicensing Settlement Agreement ("RSA") between APGI and various parties (including the North Carolina Department of Environment and Natural Resources ("DENR")). The RSA imposes certain obligations on APGI for the "protection, mitigation and enhancement of ecological, environmental, recreational and cultural resources affected by the Project under a ' The other affected waters are designated as Class WS-IV, except for a certain portion of Little Mountain Creek, which has a Class C designation. CLT 1085104v4 Mr. John Dorney November 9, 2007 Page 6 New License." Id. at Section 1.1. For example, one of the proposed license articles in the RSA requires APGI to develop and implement an approved Raze, Threatened and Endangered Species Management Plan. See Section 3.6.1. The Plan is required to address the impact of the Project operations on the bald eagle (Haliaeetus leucocephalus), as well as two other plant species. See id. Our concern is that this study schedule, to which the County did not agree, will be too late to allow a proper water quality determination under Section 401, and to allow the imposition of appropriate conditions in the final certification. The bald eagle provides a prime example.4 Bald eagles are primarily fish eaters. They generally can catch fish 6-12 inches under the surface, and they often select dead or floating fish. See http://www.carolinaraptoreenter.org/b_eagle.php. Usually, they catch fish that have come through the turbines at a dam; these fish are dazed, dead, or injured and make easy prey for the eagles. This phenomenon has been noted at the Badin Dam (Narrows Dam) in particular. See http://www.ncnatural.com/NCUSFS/Uwharrie. In general, bald eagles consume approximately 1-2 pounds of fish per day. See http://www/greatriverroad.com/Eagies/eagieSciFacts.htm. These facts are important for two reasons. First, there is no doubt that the operation of the dam system can have a critical impact on how the bald eagle gathers its primary food, given that dams are a favorite hunting ground. Indeed, one source suggests that the Badin Dam provides a prime location to view the bald eagle for just that reason. See http://www.ncnatural.comNCUSFS/Uwharrie. Second, and critically, planning is now underway to gather vital information about the Plant's potential impact on fish populations, the same fish that will be affected by the dams and eaten by the bald eagles. This information is forthcoming, but not yet available. Approximately two years after the County raised environmental and health concerns about the conditions of the Lake to Alcoa, and after a recent meeting with DENR to require Alcoa to perform additional studies of the Lake impacts, Alcoa has apparently agreed to perform a "fish study" of the potential environmental impacts to the Lake from the Plant's operations. The County understands that the design and parameters for this "fish study" will be available by November 16, 2007. Once the work plan is approved, Alcoa will presumably conduct the work outlined in the work plan and make this information available to the EPA, the North Carolina Department of a Although it was recently "delisted" under the Endangered Species Act, the bald eagle is still a critically important and protected species. For example, the bald eagle remains protected by the Bald and Golden Eagle Protection Act, which prohibits the taking of bald eagles within the United States. See 16 U.S.C. 668. Under that Act, "taking" also prohibits "disturbance," a term that was defined by the Fish and Wildlife Service in June 2007 to mean "to agitate or bother a bald or golden eagle to a degree that causes, or is likely to cause, based on the best scientific information available, (1) injury to an eagle, (2) a decrease in its productivity, by substantially interfering with normal breeding, feeding, or sheltering behavior, or (3) nest abandonment, by substantially interfering with normal breeding, feeding, or sheltering behavior." 50 C.F.R. 22.3. The term "disturb" is also broad enough to include adverse habitat modification. 72 Fed. Reg. 31133 (June 5, 2007); Contoski v, Scarlett, 2006 WL 2331180 at * 3 (D. Minn. Aug. 10, 2006). Therefore, although the bald eagle is delisted, the Bald and Golden Eagle Protection Act provides analogous protection to that afforded under the Endangered Species Act. CLT 1085104v4 Mr. John Dorney November 9, 2007 Page 7 Environment and Natural Resources ("DENR") and other interested parties. The "fish study" is vital to understanding the potential impact of managing the Lake system on species, including the bald eagle, given that fish movement and management may depend on whether and how fish populations are impacted by the contamination conditions. The County submits that DWQ must consider the results of the new fish study in its evaluation of water quality and its consideration of appropriate conditions for a Section 401 certification. In fact, while evaluating DWQ's decision on certain stormwater permits and how those permits might affect the Carolina Heelsplitter (an endangered species), a North Carolina Administrative Law Judge recently held that DENR's: legal obligation to protect biological integrity necessarily includes the protection of the most sensitive species within a watershed. Therefore, in the Goose Creek watershed, biological integrity encompasses the ability of the watershed to maintain the federally endangered Carolina Heelsplitter population. North Carolina Wildlife Fed'n et al. v. North Carolina Dep't of Env't & Natural Res., Div. of Water Quality, 05 EHR 2055 and 06 EHR 0164 at 27-28 (consolidated cases)(March 7, 2002). Preservation of biological integrity would certainly include protection of the bald eagle and other species, and the study is therefore essential to evaluating whether the Project will affect water quality standards. It also goes without saying that the fish study, and information related to biological integrity in general, is critical to understanding potential impacts on the human population. The water quality standards applicable to the Lake require, among other things, protection of uses for fish consumption and for primary recreational activities involving human body contact with water on a frequent basis. Given the potential for environmental impacts in the Lake, certainly these uses could be seriously impacted by operation of the dam system. Indeed, DENR itself argued in its February 22, 2007 Notice of Intervention and Alternative Motion to Intervene, filed in APGI's FERC license renewal process, that "[t]he operation of this project may change the quantity and quality of fish habitat in the river, alter the chemical and physical properties of the river, affect the recreational opportunities in the river, affect submerged lands to which the State retains title, etc." DENR Notice at 4. Based on DENR's own beliefs on the potential impact of the dam, it should certainly wait to review all available information, including the upcoming "fish study." In sum, the County submits that the Section 401 certification process must be extended to permit a review of all environmental information. The outstanding fish study is "information necessary to the Director's decision" that is "unavailable," thus justifying a delay in the process beyond the 60 day decision-making requirement. 15A N.C.A.C. 2H .0507(a)(5). CLT 10851044 Mr. John Domey November 9, 2007 Page 8 The 401 Certification Also Must Be Delayed To Provide Time For DENR To Evaluate Existing Information Concerning Potential Contamination Of The Lake And Its Organisms, And To Evaluate The Need To Gather New Water Quality Data Moreover, the process must also evaluate other current environmental information that (we believe) has yet to be considered. As discussed in more detail below, we do not believe that DWQ has been presented with environmental impacts that the contamination at the Plant and Lake may have on water quality standards, including the protection of the biological integrity of the Lake and the safety of the waters for the best uses of the Lake. Again, the potential for adverse impacts to the Lake and water system from the dam operation, and the appropriate conditions in a water quality certification, cannot be properly evaluated until this information is reviewed. We have provided below a brief summary of the information collected to date, and presented to DENR in other contexts, that demonstrate potential impacts to the Lake and its ecosystems. As you will see, the information both identifies current impacts and highlights the need for additional studies. A. The Screening Site Investigation of the Alcoa Badin Landfill by the Superfund Division of DENR in 1991 included an assessment of the aboveground waste pile for the disposal of spent potliners, furnace bricks and construction debris. Although the investigation identified only elevated levels of acetone in soil and groundwater, the report noted that the foot of the landfill ended in an area of seeping water. This water apparently flowed along the path of an intermittent creek leading to the Lake. The report further explained that the Lake is an "excellent fishery" for both sport and commercial fishing and "one of the best and heaviest used" in North Carolina. The Lake reportedly supported approximately 398.26 pounds per acre of fish and, as of 1980, approximately 69,408 pounds of fish were harvested and consumed per year. The County estimates that the volume of fish from the Lake consumed by humans has dramatically increased since the 1980 figures. B. The March 2001 RCRA Facility Investigation Report ("RFI") prepared by MFG, Inc. for Alcoa provides the sampling data related to environmental impacts to sediment and surface waters at the Lake. Specifically, the RFI identified the following contaminants in the sediment in the areas of the Boat Launch and Swimming Cove in the Lake above the EPA Region III Industrial Soil Risk-Based Concentration: benzo(a)pyrene, benzo(a)anthracene, benzo(a)flouranthene, dibenzo(a,h)anthracene, indeno(1,2,3-cd)pyrene, Aroclor 1242 and 1260, and arsenic.5 See RFI at 100 and Table 4-58. No contaminants were detected in surface water 5 Alcoa concluded that the concentration of arsenic in the sediments in these areas is not a constituent of concern because the detected levels were below the levels Alcoa determined to be "background" at the Plant. The County CLT 1085104v4 Mr. John Dorney November 9, 2007 Page 9 above the North Carolina 2B standards. The RFI also concluded that benzo(a)pyrene was detected in the Swimming Cove area sediments at concentrations higher than the screening values for human health. See RFI at 101 and Table 4-59. Despite the elevated levels of contaminants in sediments, Alcoa concluded that the impacted sediments would yield acceptable results regarding human health risk exposure in the swimming area, and (for areas of shallow impacts in the Boat Launch area) Alcoa basically concluded that the time of contact would be brief because of the rocky floor bottom and the water washing off sediment. Even if Alcoa is correct, however, the County submits that potential human exposure is only one piece of a large, vital puzzle. We are not aware of any review of the information in light of the overall ecosystem, whether other components of the ecosystem are impacted, and how the operation of the darn and water system might affect the distribution of those impacts through movement of organisms or otherwise.6 Moreover, in this time of severe drought, sediments that were at one time at depth are now undoubtedly much closer to the surface. Other sediments may have migrated to deeper areas that have not been sampled or otherwise studied. Understanding exposure scenarios related to the current condition of sediments contaminated by the Plant's operations is critical to management of the Lake system and the maintenance of water quality/biological integrity. Finally, the sampling data utilized in the RFI was collected in 1996 and 1997, over ten years ago. The possible presence of additional impacts to the Lake system since that time must also be evaluated. The County understands, for example, that Alcoa has been unable to meet the parameters of its NPDES permit (N00004308) for the Plant. Indeed, DENR recently granted Alcoa an extension of time (ranging from 18 to 36 months) for Alcoa to meet the discharge standards in its current NPDES permit for the following parameters: chlorine, cyanide and fluoride. Accordingly, it appears that the Plant continues to discharge pollutants to the Lake in excess of its NPDES permit, including for parameters that - based on 10-year old sampling data - exceed industrial standards in the Lake. C. The recent Characterization of the Toxicity and Bioavailability of Polycyclic Aromatic Hydrocarbons in Aquatic Sediments from Badin Lake, prepared by Retec (February 2007) assessed the Bioavailability and toxicity of Polycyclic Aromatic Hydrocarbons ("PAHs") in the sediments of the Lake adjacent to the Plant. The report identified PAHs in sediment that ranged from 0.23 ppm to 1,690 ppm, and stated that the carbon identified in the samples was consistent with the emissions from a smelter and carbon plant, and the use of coal at the smelter. does not know how DENR views either this conclusion or the appropriate standards against which to measure the results. 6 The RFI also identified elevated levels of contaminants in groundwater that the County believes may lead to adverse impacts on the Lake water quality. Indeed, the five (5) groundwater monitoring wells located downgradient from the Plant and near the Lake all identified elevated levels of contaminants. The following contaminants were identified above the applicable North Carolina 2L standards: total cyanide (MW-16, MW-25 and MW-25A); fluoride (MW-16, MW-25, MW-25A and MW-26) and trichloroethene (MW-16). See RFI at Table 4-59. CLT 1085104v4 Mr. John Dorney November 9, 2007 Page 10 The report concluded that the samples collected did not exceed the concentrations at which benthic aquatic invertebrate would be expected to have reduced survival, and that the toxicity and bioavailability of PAHs in sediment did not represent a significant source of toxicity to benthic aquatic organisms. We are not aware of DENR's reaction to this study, and whether DWQ has considered its bases and agrees with its conclusions. We do note, however, that the report apparently did not include any sampling or analysis of the potential impacts to the fish population in the Lake and/or on individuals (including children) who frequently swim and conduct other water activities in the Lake. D. There are numerous other Sources of Information that we believe would contain information relevant to evaluating environmental and water quality impacts to the Lake system deriving from the Plant. For example, among others, APGI's compliance history with its NPDES permit (No. N00081947), water quality reports for the Plant, monitoring data for the Plant, the impaired water status of Little Mountain Creek (which is part of the proposed Yadkin Hydroelectric Project), litigation records from a suit initiated by Alcoa with respect to insurance coverage for environmental contamination at the Plant, and the Toxic Release Inventory Reports for the Plant. The County's position is well known: Alcoa's record of waste contamination at the Plant, and its minimal and delayed responses to address such contamination, are directly relevant to the issue of whether Alcoa (and its wholly-owned subsidiary APGI) would be a fit environmental steward for the Yadkin Project and would conduct its operations without negative impacts to the water quality standards of the Lake.? The County intends to press its position in the FERC proceedings, and to ask FERC to assert its full authority to mitigate and improve environmental conditions at the Project, including Badin Lake. For the current purposes, it is apparent that there is a lack of a comprehensive (or current) environmental assessment of the environmental impacts to the Lake from the Plant's historic operations, and that the absence of complete and adequate information directly impacts DWQ's Section 401 certification decision. Indeed, the County's view is that, while the situation at the Plant may have improved (due largely to the shutdown of the facility), the documents already show an inextricable link between prior operations at the Plant and impacts to the Lake's water quality that would dictate that the Section 401 certification be conditioned to assure protection of water quality and biological integrity. Those conditions cannot be properly understood until all information is considered. Importantly, they also cannot be evaluated until additional information is gathered concerning impacts to the Lake and the resulting consequences for Lake management. See 15 A N.C.A.C. 2H .0502(c) and (d) (allowing DWQ to request additional information and conduct investigations necessary for the proper consideration of the application). 7 Indeed, it appears that significant remedial work remains to be performed at the Plant, Alcoa disclosed in a lawsuit against its insurance company in Washington State that the estimated cleanup costs at the Plant would be $50 million. However, to date, it appears that Alcoa has spent only $8 million to investigate and implement remedial measures at the Plant. CLT 1085104v4 Mr. John Dorney November 9, 2007 Page 11 Conclusion In sum, the County believes it is premature for DWQ to issue a Section 401 water quality certification based on the current information it has been provided and without fully evaluating the environmental impacts to the Lake from the Plant's historic operations, including information from the impending "fish study." Indeed, DENR must review this information to determine if the identified impacts to the Lake, its aquatic life and/or related species and ecosystems will be exacerbated by the operation of the dam system APGI is proposing to operate for another 50 years. We would therefore submit that DENR should deny certification at this time or otherwise hold APGI's application in abeyance, pursuant to 15A N.C.A.C. 2H .0507(a)(5), to allow DENR additional time to receive and review information necessary to its decision. The County therefore respectfully requests that DWQ not grant the 401 water quality certification, and that the process continue as necessary to consider the past and impending environmental studies and to gather adequate new information related to the agency's decision. Thank you again for your attention to this matter. Please feel free to contact me if you have any questions or require any additional information from the County along these lines. Very truly yours, Tho Griffin, III Attorne for Stanly County TNG/cmh cc: Mr. Jerry D. Myers, County Manager, Stanly County (via email only) JMyers@co. stanly. nc. us Tom Reeder, Chief, Division of Water Quality (via email only) tom.reeder@ncmail.net Paul Rawls, Division of Water Quality (via email only) paul.rawls@ncmail. net David. R. Poe, Esq., LeBoeuf, Lamb, Greene & MacRae LLP (via email only) Counsel for APGI davidpoe@llgm.com CLT 1085104A Curriculum Vitae for John H. Rodgers, Jr., Ph.D. 3/2008 CURRICULUM VITAE John H. Rodgers, Jr. BIRTHRATE: February 1, 1950 BIRTHPLACE: Dillon County, South Carolina, U.S.A. SSN: Available on request MARITAL DATA: Wife's maiden name - Martha W. Robeson Children - Daniel Joseph (Born January 16, 1978) Frank Clifford (Born July 7, 1985) HOME ADDRESS: 102 Santee Trail Clemson, SC 29631 Telephone: (864) 653-3990 PRESENT Professor POSITION: Department of Forestry and Natural Resources Clemson University Co-Director Clemson Environmental Institute Clemson University Director Ecotoxicology Program Department of Forestry and Natural Resources Clemson University PRESENT Department of Forestry and Natural Resources ADDRESS: PO Box 340317 261 Lehotsky Hall Clemson University Clemson, SC 29634-0317 Telephone: (864) 656-0492; (864) 646-2960 Fax: (864) 656-1034 Cell-phone: (864) 650-0210 E-mail: jrodger(a").clemson.edu Rodgers-1 EDUCATION: Virginia Polytechnic Institute and State University, Blacksburg, VA, Ph.D. Degree, Botany, Aquatic Ecology, 1977. Clemson University, Clemson, SC, M.S. Degree, Botany, Plant Ecology, 1974. Clemson University, Clemson, SC, B.S. Degree, Botany, 1972. PROFESSIONAL Clemson University (1998-present): EXPERIENCE: Professor, Department of Forestry and Natural Resources Co-Director, Clemson Environmental Institute Director, Ecotoxicology Program 2003 - Present. Director, Clemson Institute of Environmental Toxicology Chair, Department of Environmental Toxicology Professor, Department of Environmental Toxicology Co - Director, Clemson Environmental Institute 1998 - 2003. University of Mississippi: (Department of Biology) Professor, Department of Biology, 1989 - 1998. Director, Ecotoxicology Program, 1995 - 1998. Adjunct Research Professor, Research Institute for Pharmaceutical Sciences, 1989 - 1998. Director, Biological Field Station, 1990 - 1995. Director, Center for Water and Wetland Resources, 1993 - 1995. Associate Director, Biological Field Station, 1989 - 1990. University of North Texas: (Division of Environmental Sciences, Department of Biological Sciences) Rodgers-2 Director, Water Research Field Station, 1987 - 1989. Associate Professor, Department of Biological Sciences, 1985 - 1989. Associate Director, Institute of Applied Sciences, 1982 - 1988. Assistant Professor, Department of Biological Sciences, 1982 - 1985. Research Scientist II, Institute of Applied Sciences, 1979-1981. East Tennessee State University: (Department of Environmental Sciences, Aquatic Ecology Section) Assistant Professor, 1978 - 1979. Virginia Polytechnic Institute and State University: (Biology Department, Center for Environmental Studies) Postdoctoral Research Associate, 1977 - 1978. Research Assistant- Energy Research and Development Administration, 1975 - 1977. Clemson University (1972-1974): (Botany Department) Research Assistant - Water Resources Research Institute, 1972 - 1974. Laboratory Teaching Assistant - Plant Physiology, Plant Ecology, Biological Oceanology, Botany, 1972 -1974. MILITARY U.S. Air Force Reserve, Second Lieutenant, SERVICE: 1972 - 1975. U.S. Air Force Reserve, First Lieutenant, 1975 - 1978. U.S. Air Force Reserve, Captain, 1978 - 1984. U.S. Air Force (Active Duty), Rodgers-3 June 1 - August 29, 1976. U.S. Air Force, Honorable Discharge, 1984. Pilot Certificate - 34 hours, Single engine aircraft. RESEARCH SUPPORT: Clemson University (1972-1974): Research Assistantship, Water Resources Institute, Project No. B-053-SC ($42,000), 1972 - 1974. Impact of Thermal Effluent from a Nuclear Power Plant on Reservoir Productivity. Thesis Parts Award, USAEC, The E.I. DuPont de Nemours & Co., Savannah River Laboratory (Thermal Effects Laboratory), Aiken, S.C., 1973-1975. Effects of Elevated Temperatures on Periphyton Productivity in Lotic Aquatic Ecosystems. Savannah River Laboratory, Research Assistantship, Research Contract USAEC Funding ($50,000), 1973-1975. Impacts of Ash from Coal Combustion on Swamp Receiving Systems. Virginia Polytechnic Institute and State University: Research Assistantship, Research Contract, American Electric Power Corporation Funding ($93,000), 1974-1975. Thermal Tolerances and Electivities of Fish Adjacent to a Coal-Fired Power Plant. Research Assistantship, Research Contract, Energy Research and Development Administration Funding ($112,000),1975 - 1976. Structural and Functional Responses of Aquatic Communities to Power Generation. Research Assistantship, Research Contract, Energy Research and Development Administration Funding ($132,000),1976 - 1977. Responses of Aquatic Communities to Perturbations Associated with Power Generation. Co-principal Investigator, Research Contract, Water Resources Research Institute Funding ($68,000), 1977 - 1979. Environmental Tolerances of Corbicula fluminea from the New River, Virginia. East Tennessee State University: Principal Investigator, Research Contract, ETSU Research Development Committee Rodgers-4 Funding ($3,270), 1978 - 1979. Primary Production and Nutrient Dynamics in the Watauga River, Tennessee. Oak Ridge Associated Universities Travel Contract, 1978 - 1979. Impacts of Power Production on Aquatic Ecosystems of Savannah River Laboratory. University of North Texas: Co-Principal Investigator, Research Contract, Chemical Manufacturers' Association Funding ($80,000), 1979 - 1980. Modeling the Fate of Chemicals in Aquatic Environments. Principal Investigator, Research Contract, NTSU Faculty Research Grant Funding ($4,000), 1979 -1980. Biotransformation of Xenobiotics in Aquatic Systems. Co-principal Investigator, Research Contract, International Paper Company Funding ($149,530), 1980 - 1981. Impacts of Paper Mill Effluent on Aquatic Ecosystems. Co-principal Investigator, Research Contract, Victor Equipment Company Funding ($5,000), 1980. Optimization of Packaged Waste Treatment System for Metal Removal. Co-principal Investigator, Research Contract, International Paper Company Funding ($171,830),1980 -1981. Investigation of Pre- and Post-Operational Effects of a Paper Mill on Aquatic Systems. Principal Investigator, Research Contract, NTSU Faculty Research Grant Funding ($4,620), 1980 - 1981. Predicting Bioconcentration of Chemicals by Aquatic Organisms. Co-principal Investigator, Research Contract, Chemical Manufacturers' Association Funding ($30,000), 1981. Validation of Chemical Fate Models for Aquatic Ecosystems. Co-principal Investigator, Research Contract, U.S. Environmental Protection Agency Funding ($305,866), 1981 - 1983. Development of a Decision Support System for Integrated Management of Nuisance Aquatic Vegetation. Principal Investigator, Research Contract, NTSU Faculty Research Grant Funding ($3,600), 1981-1982. Fate and Effects of the Herbicide, Endothall, in Aquatic Systems. Co-principal Investigator, Research Contract, Chemical Manufacturers' Association Funding ($59,985), 1981 - 1982. Studies of Fate and Effects of Chemicals in Aquatic Ecosystems. Co-principal Investigator, Research Contract, International Paper Company Funding ($113,000), 1982. Effects of Paper Mill Effluent on Aquatic Ecosystems. Rodgers-5 Principal Investigator, Research Contract, U.S. Army Corps of Engineers Funding ($24,500), 1982. Ecosystem Study of Pat Mayse Lake, A Southwestern Reservoir. Co-principal Investigator, Research Contract, International Paper Company Funding ($348,926), 1982 - 1985. Further Studies of Effects of Paper Mill Effluent on Aquatic Ecosystems. Principal Investigator, Research Contract, NTSU Faculty Research Grant Funding ($3,500), 1982 - 1983. Proximate Oxygen Demand of Aquatic Plants. Co-principal Investigator, Research Contract, U.S. Environmental Protection Agency Funding ($199,500), 1982 - 1983. Validation of Decision Support Systems for Integrated Management of Nuisance Aquatic Vegetation. Co-principal Investigator, Research Contract, American Petroleum Institute ($83,809), 1981 - 1982. Bioavailability of Petroleum-Derived Chemicals in Aquatic Ecosystems. Principal Investigator, Research Contract, U.S. Army Corps of Engineers Funding ($25,000), 1983. Further Studies: Pat Mayse Lake, A Southwestern Reservoir. Principal Investigator, Research Contract, U.S. Army Corps of Engineers Funding ($1,000), 1983. Remote Sensing of Aquatic Vegetation in Pat Mayse Lake. Co-principal Investigator, Research Contract, Shell Development Company Funding ($17,000), 1983. Impact of Petroleum Compounds on Aquatic Organisms. Principal Investigator, Research Contract, NTSU Faculty Research Grant Funding ($4,500), 1983 - 1984. Threshold Responses of Aquatic Vegetation to Herbicides. Co-principal Investigator, Research Contract, Shell Development Company Funding ($29,758),1984. Inter-Laboratory Comparison of Bioassays Using Freshwater and Marine Organisms. Principal Investigator, Research Contract, U.S. Army Corps of Engineers Funding ($20,000), 1984. Water Quality Monitoring and Aquatic Vegetation in Pat Mayse Lake. Principal Investigator, Research Contract, Pennwalt Corporation Funding ($11,500), 1984. Comparative Study of Two Aquatic Herbicides. Principal Investigator, Research Contract, Shell Oil and Chemical Company Funding ($14,000). Aquatic Toxicology Studies for the Petrochemical Industry. Principal Investigator, Research Contract, Dallas County Utility and Reclamation District Rodgers-6 Funding ($12,000), 1984 - 1985. Eutrophication Potential in an Impoundment Receiving Wastewater. Co-principal Investigator, Research Contract, Shell Development Company Funding ($31,797), 1985. Development of Data on Proper Selection of Bioassay Species. Co-principal Investigator, Research Contract, Texas Instruments, Inc. Funding (approximately $12,000, equipment), 1985. Development of Expert Systems for Water Quality Management. Principal Investigator, Research Contract, U.S. Army Corps of Engineers Funding ($24,500), 1985. Development of a Water Quality Model and Lake Management Strategy for Pat Mayse Lake. Co-principal Investigator, Research Foundation Award, Shell Research Foundation ($15,000), 1985. The Response of Marine and Freshwater Species to Xenobiotics. Principal Investigator, Research Contract, NTSU Faculty Research Grant Funding ($2,700), 1986 - 1987. Experimental Analysis of Bioassay Methods. Co-principal Investigator, Research Contract, U.S. Army Corps of Engineers Funding ($168,693), 1986 - 1987. Ecological Analysis of the Lake Ray Roberts Project Site. Principal Investigator, Research Contract, U.S. Army Corps of Engineers Funding, ($68,000), 1986 - 1987. Coupling an Environmental Fate and Effects Model for 2, 4-D and Water Hyacinth. Co-principal Investigator, Research Contract, Shell Research Foundation Funding ($15,000), 1986. Osmoregulation in Marine Bioassay Species. Principal Investigator, Research Contract, American Petroleum Institute Funding ($8,000), 1986. Evaluation of Marine Bioassay Species. Principal Investigator, Research Contract, American Petroleum Institute and U.S. Environmental Protection Agency Funding ($10,000), 1986. A Workshop on Culture and Life History of Mysidopsis sp. Co-principal Investigator, Research Contract, Shell Research Foundation Funding ($20,000), 1987. Sediment Organic Carbon Content in Aquatic Systems of the U.S. Principal Investigator, Research Contract, U.S. Army Corps of Engineers Funding ($24,500), 1987 - 1988. Endothall Fate and Effects on Myriophyllum spicatum in Pat Mayse Lake, Texas. Rodgers-7 Co-principal Investigator, Research Contract Hoechst-Roussel Agri-Vet (Hoechst- Celanese) Co. Funding ($185,000), 1987 - 1988. Development of Mesocosms and Water Research Field Station. Co-principal Investigator, Research Contract, City of Dallas Funding ($319,964), 1987 - 1989. Ecological Survey and Study of the Trinity River, Texas. Co-principal Investigator, Research Contract, Hoechst-Roussel Agri-Vet (Hoechst- Celanese) Co. Funding ($325,000), 1988 - 1989. Fate and Effects of Tralomethrin in Mesocosms. Co-principal Investigator, Research Contract, Hoechst Roussel Agri Vet (Hoechst-- Celanese) Co. Funding ($185,000), 1988 - 1989. Further Development of Mesocosms and Water Research Field Station. Principal Investigator, Research Contract, U.S. Army Corps of Engineers Funding ($24,500), 1988 - 1989. Further Development of a Water Quality Model and Lake Management Strategy for Pat Mayse Lake. Principal Investigator, Research Contract, U.S. Army Corps of Engineers Funding ($24,550), 1988 - 1989. Research on SONAR in Pat Mayse Lake. Principal Investigator, Research Contract, U.S. Army Corps of Engineers Funding ($107,000), 1988-1989. Water Research Field Station-Coupling a Herbicide Fate and Effects Model. Principal Investigator, Research Contract, Pennwalt Corporation ($2,000), 1988-1989. Degradation of Endothall by Chlorine. Co-principal Investigator, Research Contract, Mobay Corporation ($852,000), 1988- 1990. Fate and Effects of Cyfluthrin in Mesocosms. Co-principal Investigator, Research Contract, Shell Development Corporation ($55,000) 1989-1990. Bioavailability of Sediment-sorbed Chemicals to Freshwater Organisms. University of Mississippi: Principal Investigator, Research Contract U.S. Army Corps of Engineers - Tulsa District Funding ($24,500), 1988-1989. Limnology and Aquatic Botany of Pat Mayse Lake, Texas. Principal Investigator, Research Contract, Shell Development Company Funding ($50,000), 1989-1990. Evaluation of Sediment Toxicity Testing Procedures. Rodgers-8 Co-principal Investigator, Research Contract Soil Conservation Service Funding ($50,000), 1990-1991. Wetlands for Interception and Processing of Pesticides in Agricultural Runoff. Co-principal Investigator, Research Contract Tennessee Valley Authority Funding ($171,410), 1990-1991. Analysis of Aquatic Herbicides in Lake Guntersville, Alabama for the Aquatic Plant Management Program. Principal Investigator, Research Contract, Ciba Giegy Corporation Funding ($31,000), 1990. Effects of Atrazine on Aquatic Vascular Plants. Co-principal Investigator, Research Contract, Dow-Elanco Corporation Funding ($40,000), 1990. Analysis of Fluridone in Florida Aquatic Plant Management Programs. Principal Investigator, Research Contract, U.S. Environmental Protection Agency - Gulf of Mexico Program ($17,565) 1990-1991. Assistance with the Citizen's Advisory Group of the Gulf of Mexico Program. Co-principal Investigator, CHP International, Inc. (U.S. Peace Corps) Funding ($22,000), 1990. Aquaculture Training Sessions for Volunteers for Africa. Co-principal Investigator, University of Mississippi Funding ($1,000), 1989-1990. Water Systems for an Aquatic Toxicology Laboratory. Principal Investigator, Internal Equipment Funding, University of Mississippi Associates Funding ($25,000), 1990-1991. Aquisition of an Ion Chromatograph/High Performance Liquid Chromatograph. Principal Investigator, U.S. Army Corps of Engineers, Waterways Experiment Station Funding ($250,000), 1990-1993. Development of Controlled Release Herbicides for Aquatic Use. Principal Investigator, American Petroleum Institute Funding, ($250,000), 1990 -1992. Reference Toxicants and Reference Sediments for Sediment Toxicity Testing. Principal Investigator, Research Contract, Tennessee Valley Authority Funding ($168,000), 1991-1992. Aquatic Herbicides in Guntersville Reservoir, Alabama - National Demonstration Project. Co-principal Investigator, Research Contract, U.S. Department of the Army, Vicksburg District, Corps of Engineers Funding ($96,036), 1991-1992. Monitoring Water Quality at Arkabutla, Enid, Grenada, and Sardis Lakes. Rodgers-9 Principal Investigator Research Contract ABC Laboratories Inc. and Zoecon , Corporation Funding ($10,000), 1991. Outdoor Microcosm Study of an Insect Growth Regulator. Co-principal Investigator, Research Contract, Shell Development Company Funding ($192,000), 1991-1993. Development of a Model Stream Facility and Evaluation of the Environmental Safety of a Surfactant. Principal Investigator, Research Contract, U.S. Army Waterways Experiment Station Funding ($25,000), 1991-1992. Evaluation of New Herbicide Delivery System for Control of Aquatic Plants. Principal Investigator, Research Contract, U.S. Army Waterways Experiment Station Funding ($64,000), 1992-1993. Evaluation of New Herbicide Delivery Systems for Control of Aquatic Plants. Principal Investigator, Research Contract, American Petroleum Institute Funding ($100,000), 1992-1993. New Sediment Bioassays and Reference Sediments. Principal Investigator, Mississippi State Department Of Wildlife, Fisheries, and Parks Funding ($6,000), 1991-1993. Cooperative Agreement for Assistance with Walleye Culture. Co-Principal Investigator, Research Contract, U.S. Army Corps of Engineers Funding ($100,848), 1992-1993. Monitoring of Water Quality at Arkabutla, Sardis, Enid, and Grenada Lakes. Principal Investigator, Mississippi State Department of Wildlife, Fisheries and Parks Funding ($3,000), 1992-1993. Cooperative Agreement for Assistance with Walleye Culture. Principal Investigator, Research Contract, Funding ($30,000), 1992-1994. Mobility ai Contaminants. U.S. Army Waterways Experiment Station d Bioavailability of Sediment Associated Principal Investigator, Research Contract, U.S. Army Waterways Experiment Station Funding ($25,000), 1992-1993. Effects of Food Quantity on Fathead Minnow Survival, Growth and Reproduction. Principal Investigator, Research Contract, Eastman Kodak and the Silver Coalition Funding ($53,183), 1992-1994. Evaluations of the Bioavailability and Toxicity of Silver in Sediments. Principal Investigator, Research Contract, Shell Development Company Funding ($150,000), 1992-1993. Ecological Evaluation of a Non-ionic Surfactant in Model Stream Mesocosms. Rodgers-10 Principal Investigator, Research Contract, Shell Development Company Funding ($30,342), 1993-1994. Assistance with Development and Construction of Constructed Wetlands for Tertiary Treatment of Refinery Effluent. Principal Investigator, U.S. Department of Agriculture/ Cooperative State Research Service Funding ($1,377,400), 1994-1995. Center for Water and Wetland Resources (Year 4). Co-Principal Investigator, Research Contract, International Paper Company Funding ($99,631), 1994-1995. Extensive Ecological and Toxicological Evaluation of the Arkansas River at Pine Bluff, AR. Co-Principal Investigator, Research Contract, International Paper Company Funding ($99,631), 1994-1995. Extensive Ecological and Toxicological Evaluation of the Yazoo River near Vicksburg, MS. Principal Investigator, Research Contract, Shell Development Company Funding ($150,000), 1994-1995. Ecological Evaluation of a Homologus Non-ionic Surfactant in Model Stream Mesocosms. Principal Investigator, Research Contract, Shell Development Company Funding ($144,242), 1994-1996. Evaluation of Constructed Wetlands for Tertiary Treatment of Refinery Effluent. Principal Investigator, Research Contract, Texaco, Inc. Funding ($20,000), 1995-1996. Evaluation of a Constructed Wetland for Removal of Ammonia from a Refinery Effluent. Principal Investigator, Research Contract, Texaco, Inc. Funding ($20,000), 1995-1996. Evaluation of a Constructed Wetland for Removal of Trace Metals from a Refinery Effluent. Clemson University (1998-present): Principal Investigator, Assistance with Design and Construction of a Wetland for Wastewater Treatment Sponsored by Shell Oil Products from 4/1/98 to 4/1/00 ($10,000). Principal Investigator, Evaluation of the Tombigbee River. Sponsored by Weyerhauser, Inc. 1/98 - 1/02 ($22,000). Principal Investigator, Constructed Wetland for Wastewater Treatment at IP's Mansfield, LA Facility, Sponsored by International Paper Company 8/98 - 12/00 ($18,250). Rodgers-11 Principal Investigator, Investigations of Pesticide Toxicity, Sponsored by Applied Biochemists, Inc. 1/00 - 1/01 ($10,000). Principal Investigator, Wetlands for Wastewater Treatment at Savannah River Site Sponsored by DOE thru SCUREF (SC Universities Research and Education Foundation) from 1/14/99 to 2/28/00 ($28,088). Principal Investigator, A-01 Outfall Constructed Wetlands Sponsored by DOE thru Westinghouse Savannah River thru SCUREF from 7/11/99 to 9/30/00 ($624,730). Principal Investigator, Design and Construction of a Wetland for Effluent Treatment. Sponsored by International Paper Company 6/00 - 7/01 ($25,000). Principal Investigator, Evaluation of Foam Products. Flexible Products, Inc Funding from 9/99 - 1/01 (15,000). Principal Investigator, US Department of Interior Funding ($43,106), 2002-2004. Renovating Water for Conservation and Reuse. Co-Principal investigator, US Department of Agriculture Funding ($539,677), 2002- 2004. Adhesion-Specific Nanoparticles for Removal of Campylobacter jejuni from Poultry. Principal Investigator, Duke Energy Corporation Funding ($54,473). 2001. Evaluation of the Oconee Nuclear Station Conventional Waste Treatment System. Principal Investigator, Chevron Texaco Inc. Funding ($24,000), 2001-present. Evaluation of Best Management Practices for Stormwater and Other Contaminated Waste Streams. Principal Investigator, US Department of Energy Funding ($26,024). 2001-2003. A01 Constructed Wetland Treatment Facility Redox Probe Maintenance and Consultation for the Savannah River Site (from WSRC through SCUREF). Principal Investigator, U.S. Department of Interior Funding ($43,106). 2002-2003. Renovating Water for Conservation and Reuse. Principal Investigator, Sustainable Universities Initiative ($7,000). 2002-2003. A Constructed Wetland Treatment System: A Green and Sustainable Solution to Prevent Water Pollution on Campus. Principal Investigator, Duke Energy Corporation in Cooperation with Progress Energy Funding ($187,000). 2003-2004. Treatment of Mercury, Selenium and Other Targeted Constituents in FGD Wastewater: A Constructed Wetland Pilot Study. Rodgers-12 Principal Investigator, Chevron Corporation Funding ($33,600). 2003-2004,. Panama Storm Water Treatment Wetland. Principal Investigator, Griffin Corporation Funding ($20,0000). 2002-2003. Response of Aluminum from Boat Pontoons to Komeen Exposures in Lake Murray, SC Water (with Sediments and Hydrilla. Principal Investigator, Alabama Power Company Funding ($75,000). 2004-2006. Development of Strategies for Controlling Nuisiance Growths of Lyngbya in Alabama Power Company Reservoirs. Principal Investigator, Department of Energy Funding ($125,000) 2004-2005. Designing constructed wetlands to treat gas storage produced waters. Principal Investigator, Duke Energy Corporation in Cooperation with Progress Energy Funding ($105,000). 2004-2005. Continuing Studies of Treatment of Mercury, Selenium and Other Targeted Constituents in FGD Wastewater Using a Constructed Wetland Treatment System. Principal Investigator, U.S. Department of Energy Funding ($300,000) 2005-2008. Innovative Techniques for Remediation of Nontraditional Waters for Reuse in Coal-Fired Power Plants. Principal Investigator, Duke Energy Corporation and ENTRIX Funding ($100,000) 2006- 2007. Further Evaluations of Constructed Wetland Treatment Systems for Flue Gas Desulfurization Waters. Co-Principal Investigator, Chevron-Texaco Funding ($50,000) 2006-2007. Evaluation of Boron Biogeochemistry in Constructed Wetlands. Co-Principal Investigator, Monsanto Company Funding ($300,000) 2006-2008. Potential Effects of Glyphosate Formulations on Amphibians. Principal Investigator, Florida Department of Environmental Protection Funding ($60,000) Effects of Invasive Algae in Crystal River, FL and Potential Control Strategies to Protect the Florida Manatee. Co-Principal Investigator, Chevron-Texaco Funding ($50,000) Specifically Designed Constructed Wetland Treatment Systems for Produced Water in Chad. Principal Investigator, Duke Energy Corporation and ENTRIX Funding ($30,000) 2007- 2008. Additional Evaluations of Constructed Wetland Treatment Systems for Flue Gas Desulfurization Waters. Rodgers-13 Co-Principal Investigator, Clemson University Funding ($50,000) 2006-2008. Evaluation of Constructed Wetland Treatment Systems for Parking Lot Stormwater (with Dr. Rockie English). Principal Investigator, Applied Biochemists, Inc. Funding ($36,000) 2006. Approaches for Mitigation of Risks from Harmful Algal Blooms. HONORS AND AWARDS: Phi Sigma Doctoral Research Award, April, 1977. Sigma Xi Doctoral Research Award, May, 1978. Who's Who in the South and Southwest, 1979. Personalities of the South, 1981. International Who's Who, 1981. Directory of Distinguished Americans, 1981. Men of Achievement (International Biographical Center), 1981. Phi Kappa Phi Honor Society, 1982. Gordon Research Conference Travel Award, 1982. NTSU President's Award to the Institute of Applied Sciences, 1985. Mortar Board NTSU "Top Prof"Teaching Award, 1985. Elected to NTSU Graduate Faculty, 1987. Co-author - Best Student Paper (Burton Suedel and Phil Clifford), published in 1992 in Environmental Toxicology and Chemistry. Certificate of Appreciation, 1993 Mississippi Region 7 Science and Engineering Fair. 1993. Designated "Distinguished Southerner" by Editors Of Southern Living. Article on Water Watchdogs In April, 1994 edition of Southern Living. Rodgers-14 Co-author - Best Student Paper (Arthur Dunn), Mid-South Aquatic Plant Management Society. Birmingham, AL. 1994. Certificate of Appreciation, Environmental Biology Review Panel, U.S. EPA, January, 1995. President, Oxford Exchange Club - Prevention of Child Abuse, 1996-1998. Board of Directors, Society of Environmental Toxicology and Chemistry, 1989-1991; 1995-2001. Executive Committee 1997-2000. Vice President 1998-1999. President 1999-2000. Member, Expert Advisory Committee, Canadian Network of Toxicology Centres. Environment Canada and Health and Welfare, 1992-2000. Chair, Expert Advisory Committee, Canadian Network of Toxicology Centres, Environment Canada and Health and Welfare, 1996-1999. Who's Who Among America's Teachers, 7t" ed. 2002. p. 400. Certificate of Appreciation for Outstanding Service to the Society of Environmental Toxicology and Chemistry, 2003. RESEARCH AND TEACHING INTERESTS: Teaching Interests: I have taught General Botany, General Biology Environmental Biology, Assessment of Water Quality, Water Quality Management, Environmental Analysis, Aquatic Toxicology, Limnology, Microbial Ecology, Radioisotopes, and Research Techniques, Aquatic Botany, Aquatic Microbiology, Sediment Toxicology, and Analysis of Biological Data, Ecological Risk assessment, Plant Physiology, and Water Chemistry. My teaching interests also include: Plant Ecology, Wetland Ecology, and Phycology. Research Interests: Effects of heated effluents and other perturbations on primary productivity of vascular and non-vascular plants in terrestrial and aquatic systems. In situ measurements of assimilatory sulfate reduction by periphytic organisms (algae, bacteria, and fungi), sulfur content and cycling in aquatic systems. Physical models of aquatic systems as tools for the study of acute and chronic effects of Rodgers-15 industrial and power plant effluents on structural and functional aspects of aquatic microbial communities with emphasis on photosynthesis and sulfate assimilation. Production, decomposition and role in nutrient cycling of aquatic macrophytes. Impact of ash from industrial and power production processes on receiving systems and indigenous biota. Decomposition and role of autochthonous and allochthonous detritus in aquatic and terrestrial systems with emphasis on the influences of macro-invertebrates, bacteria and fungi. Invasion rates, population dynamics and elemental accumulation of the Asiatic Clam (Corbicula fluminea). Extracellular products and other organic compounds as regulating factors of structural and functional aspects of aquatic microbial communities. Benthic metabolism and physical and biological sediment characterization (using SCUBA-implemented techniques) as an index of eutrophication rates. Electron transport system activity of benthic microflora as a pollution monitoring tool. Serum enzymes of fish as an indicator of the quality and quantity of mixed effluents and their effects on receiving systems. Ecosystem responses to stress in aquatic systems; Ecological risk assessment. Relationships between carbon quantity and quality in ecosystems. Responses of microbes (algae, bacteria, and fungi) to magnetic fields. Ecological impacts associated with pulp and paper mills. Biology and ecology of Taxodium distichum (Bald cypress) swamps in the Southwest. Development of models for integrated control of nuisance aquatic vegetation and aquatic ecosystem management. Microcosms and mesocosms as tools for ecological and environmental research. Reservoir limnology and eutrophication. Secondary aquatic plant products and biocontrol of aquatic plants. Rodgers-16 Bioavailability of xenobiotic chemicals (e.g. pesticides) to aquatic organisms. Sediments as sources and sinks for contaminants in aquatic ecosystems. Population biology and physiological ecology of aquatic plants. Artificial Intelligence in ecological problem solving. Constructed wetlands for rehabilitation and wastewater treatment. Metal speciation and bioavailability. ORGANIZATIONS: American Society of Limnology and Oceanography, Ecological Society of America, American Water Resources Association, North American Benthological Society, Water Pollution Control Federation, Phi Sigma Society Alpha Psi (VPI&SU) Chapter, Sigma Xi (VPI&SU) Chapter, American Institute of Biological Sciences, American Association for Advancement of Science, Phi Kappa Phi (NTSU) Chapter, Aquatic Plant Management Society, Society of Environmental Toxicology and Chemistry. OTHER PROFESSIONAL ACTIVITIES: Consulting Aquatic Ecologist Microbiology Department, Clemson University, 1973-1975. Investigator on Facilities Use Agreement #15 at Savannah River Laboratory in conjunction with Clemson University and VPI & SU, 1973-1975. Consulting Aquatic Ecologist to American Electric Power Service Corporation, Canton, Ohio, 1974 - 1975. Investigator on Facilities Use Agreement #28 at Savannah River Laboratory in conjunction with University of Texas, School of Public Health and VPI&SU, 1975 - 1979. Consulting Microbial Ecologist to Bioengineering Research and Development Group, Oak Ridge National Laboratory, Oak Ridge, Tennessee, 1977. Consulting Aquatic Ecologist to Virginia State Water Control Board, Richmond, 1977. Rodgers-17 Invited lecturer in Plant Ecology and Environmental Biology, Botany Department, Clemson University, 1977. Consulting Aquatic Ecologist to Center for Environmental Studies VPI&SU, 1978 - 1979. Participant in Savannah River National Environmental Research Park meeting on Aquatic Research, Aiken, S.C., 1978. Grant Proposal Review for the Division of Environmental Biology of the National Science Foundation, 1978 - 1987. Consulting Aquatic Ecologist to Tennessee Eastman Company, Kingsport, Tennessee, 1978 - 1979. ETSU Research Development Committee Presidential Appointment 1978 - 1979. Consulting Aquatic Ecologist to Victor Equipment Company, Denton, Texas, 1980 - 1983. Review of publications for American Society for Testing and Materials Consulting Aquatic Ecologist to Environmental Biology Group, Oak Ridge National Laboratory, Oak Ridge, Tennessee, 1980. Gordon Research Conference Participant (Environmental Sciences - Water), 1980. Participant in Workshop on the role of aquatic microcosms in evaluating ecosystem effects of chemicals under the Toxic Substances Control Act (USEPA sponsored), 1980. NTSU representative to Texas Systems of Natural Laboratories. (Presidential Appointment), 1981 - 1986. Consulting Aquatic Ecologist to Environmental Systems Branch, U.S. Environmental Protection Agency, 1981. School of Community Service Computing Services Advisory Council (Dean's Appointment), 1981-1986. NTSU Biosafety Committee (Presidential Appointment), 1980 - 1987. Peer Review of Research Program for Environmental Systems Branch of the U.S. Environmental Protection Agency (with H.T. Odum), 1981. Rodgers-18 Participant in Workshop on Modeling the Fate of Chemicals in the Aquatic Environment (USEPA sponsored), Pellston, MI, 1981. Co-chaired session on Microcosm Testing in Aquatic Toxicology at the Society of Environmental Toxicology and Chemistry's Annual Meeting, Washington, D.C., 1981. Elected to Editorial Board of Environmental Toxicology and Chemistry, 1981- 1983. Research advisor to the Ecosystem Branch of the U.S. Environmental Protection Agency, Las Vegas, 1982. Gordon Research Conference Participant (Environmental Sciences-Water), 1982. President, Sigma Xi, NTSU Club, 1982-1983. Chair, Employment Service Committee of the Society of Environmental Toxicology and Chemistry, 1982 - 1984. Review of manuscripts for Ecological Society of America, 1981 - present. College of Arts and Sciences Committee on Interdisciplinary Research (Dean's Appointment), 1983. Department of Biological Sciences Radiation Safety Officer, 1983 - 1987. Participant, Workshop on Bioavailability of Chemicals from Dredged Materials (U.S. Army Corps of Engineers sponsored) Vicksburg, Mississippi, 1984. Consulting Aquatic Ecologist to the City of Reno, Nevada, 1983 - Mitigation of Impacts of Population Growth and Development on Lake Tahoe, Truckee River and Pyramid Lake. Consulting Aquatic Ecologist to the Las Colinas Development, 1983 - Impacts of Development on the Trinity River and Watershed. School of Community Services Committee on Resources and Nontraditional Education (Dean's Appointment), 1983 -1984. Peer review of research programs of the Naragansett Bay, R.I., U.S. Environmental Protection Agency Research Laboratory (elected chairman of the review team), 1984. North Texas State University Committee on Science and Technology (Presidential Appointment), 1984. Rodgers-19 President, J.K. G. Silvey Society, North Texas State University, 1983 - 1984. Invited Attendee, Society of Petroleum Industry Biologists, Annual Meeting, Houston, Texas, 1984. Chair of the Annual Meeting of the Society of Environmental Toxicology and Chemistry, St. Louis, Missouri, Nov. 10-14, 1985. Participant - Workshop on the Bioavailability of Sorbed Chemicals (U.S. Environmental Protection Agency and American Petroleum Institute sponsored) Florissant, Colorado, 1984. Faculty Committee Member, Cooperative Education Program of the Institute of Applied Sciences, 1984. Faculty Representative for the Sciences, elected to NTSU Faculty Senate, 1986. Served as Chairman of Placement Committee of Aquatic Plant Management Society, 1987. Peer review of research programs of the Gulf Breeze, FL., U.S. Environmental Protection Agency Research Laboratory (with H. Bergman and K. Solomon), 1987. Consulting aquatic ecologist to the City of Dallas (Water Utilities), Algal Workshop, 1987. Consulting aquatic toxicologist to the American Petroleum Institute, Bioavailability of Chemicals Sorbed to Sediments, 1987. Consulting aquatic ecologist to the Association of Central Oklahoma Governments, Use Attainability Study of Crutcho Creek and the North Canadian River, 1987. Chair, Professional Opportunities Committee (Placement) of the Aquatic Plant Management Society, 1987. Co-chair (with L. Goodman), Workshop on Mysid Culture and Testing, at the Eighth Annual Meeting of the Society of Environmental Toxicology and Chemistry, Pensacola, FL, 1987. Co-chair, sessions on Perspectives of Water Quality-Based Permitting and Field Validation of Laboratory Results, at the Eighth Annual Meeting of the Society of Environmental Toxicology and Chemistry, Pensacola, FL, 1987. Appointed to the South Carolina Aquatic Plant Management Commission, 1987. Rodgers-20 Presented short courses on Aquatic Plant Management in Texas, 1987. Presented seminars at short courses on Aquatic Plant Management in Florida, Ft. Lauderdale and Orlando, FL, 1987. Advisor on American Petroleum Institute Study of Bioavailability of Sediment Bound Chemicals (with P. Chapman and C. Missimer), 1987 - 1988. Participated in a Workshop on Mesocosm Research Sponsored by USEPA, Duluth, MN, 1987. Promotion review team member for P.R. Parrish, Environmental Research Laboratory, Gulf Breeze, FL, 1987. Chair, session on Sediment Criteria Development and Testing at the South Central Chapter Meeting of the Society of Environmental Toxicology and Chemistry, Houston, TX, 1987. Scientific Advisory Group, Proctor and Gamble Corporation, Cincinnati, Ohio, 1988, Scientific Advisory Group, Botanical Research Institute of Texas (BRIT). Fort Worth, TX, 1988. Adjunct Faculty, University of Guelph. Guelph, Ontario, Canada, 1988-1990. Invited participant, North American Benthological Society Annual Meeting. Blacksburg, VA, May 22, 1990. Invited participant, Association of Southeastern Biologists Special Workshop on Teaching the Limnology Laboratory. Baltimore, MD, April 20, 1990. Invited participant, Aquatic Plant Management Meeting. Mobile, AL, July 16, 1990. Chair, Education Committee of the Society of Environmental Toxicology and Chemistry, 1989-1991. Chair, Professional Opportunities Committee of the Aquatic Plant Management Society, 1989-1991. Chair, Discussion session on Wetlands Toxicology At the Society of Environmental Toxicology and Chemistry Annual Meeting. Washington, D.C., November 12, 1990. Member, Aquatic Effects Dialogue Group of the Conservation Foundation, 1989-1991. Rodgers-21 Member, Advisory Group to the World Wildlife Fund, 1989-1991. Consulting Aquatic Ecologist and Toxicologist to Proctor and Gamble Company. Cincinnati, OH, 1989-1991. Served on a discussion panel on the Future of Aquatic Plant Management with emphasis on regulatory issues regarding herbicides at the 25th Annual Meeting of the Aquatic Plant Control Research Program - U.S. Army Corps of Engineers. Orlando, FL, November 26-30, 1990. Served on a discussion panel on the Future of Aquatic Plant Management with Emphasis on Simulation Technology and Modeling at the 25th Annual Meeting of the Aquatic Plant Control Research Program - U.S. Army Corps of Engineers. Orlando, FL. November 26-30, 1990. Consulting Aquatic Toxicologist, U.S. Environmental Protection Agency, Ecorisk Program evaluation. 1990-1991. Consulting Aquatic Toxicologist, International Paper Company. 1990-1991. Consulting Aquatic Toxicologist, State of Mississippi. 1990-1991. Consulting Aquatic Toxicologist, Environment Canada, Health and Welfare Canada - Canadian Network of Toxicology Centers, Expert Advisory Committee. 1991- 2001. Consulting Aquatic Toxicologist, Ecorisk Forum on the Rocky Mountain Arsenal Refuge Technical Expert Advisory Panel. 1991-1992. Consulting Biologist and Ecotoxicologist, Arkansas Department of Higher Education and Arkansas State University Ph.D. Program Development. 1991- 1998. Invited participant, Tiered Testing Issues for Freshwater and Marine Sediments, sponsored by U.S. EPA Office of Water and Office of Research and Development. Washington, D.C., September 16-18, 1992. Invited speaker, Workshop on the Bioavailability and Toxicity of Copper, sponsored by the University of Florida, Center for Aquatic Plants. Gainesville, FL, September 2-3, 1992. Peer reviewer for U.S. EPA, Framework for Ecological Assessment, Risk Assessment Forum. Washington, D.C., 1992 (EPA/130/R-92/001 - February 1992). Invited speaker, 4th Annual Meeting of the Soil and Water Conservation Society. Rodgers-22 Baltimore, MD, August 9-12, 1992. Participant, U.S. EPA Workshop on Bioaccumulation of Hydrophobic Chemicals. Washington, D.C., June,1992. Invited lecturer and participant, Young Scholars Program, NSF funded. Oxford, MS, 1992. Counselor for summer interns with the Minorities Science Program, University of Mississippi funded. Oxford, MS, 1992. Peer Review, Biology Peer Review Panel, U.S. EPA. Knoxville, TN, January, 1993. Conference Co-organizer, First International Conference on Transport, Fate, and Effects of Silver in the Environment. University of Wisconsin, Madison, WI, August 8-10, 1993. Chair, Exhibits Committee, 14th Annual Meeting of the Society of Environmental Toxicology and Chemistry. Houston, TX, November, 1993. Consulting Aquatic Ecologist and Toxicologist to Weyerhaeuser Corporation. Columbus, MS, 1994 - 1999. Member, Student Scholarship Committee, Mid-South Aquatic Plant Mangement Society. 1994 - 1997. OSHA Safety Course. Norco, LA, 1994. Joint Agency Task Force Member, Guntersville Project. Guntersville, AL, April, 1994. Featured speaker, Seminar on Pollution Prevention for Silver Imaging Systems. Lake Buena Vista, FL. May, 1994. Conference Organizer, Second International Conference on Transport, Fate and Effects of Silver in the Environment. University of Wisconsin, Madison, WI, September 11-14, 1994. Chair - Subcommittee, National Institute of Environmental Health Sciences (NIEHS) - Superfund Hazardous Substances Basic Research Program. Research Triangle Park, NC, October 16-19, 1994. Discussion Panel Participant, 2nd International Conference on Environmental Fate and Effects Of Bleached Pulp Mill Effluents. Vancouver, B.C., Canada, November, 1994. Genetic Toxicology Course (Audit). Oxford, MS, 1995. Rodgers-23 Board of Directors, Society of Environmental Toxicology and Chemistry (elected), 1995. Participant, U.S. EPA Environmental Biology Review Panel. Fort Worth, TX, January, 1995. Participant, Society of Environmental Toxicology and Chemistry Workshop on Wetlands. Butte, MT, August, 1995. Conference Organizer, Third International Conference on Transport, Fate and Effects of Silver in the Environment. Washington, D.C., August, 1995. Featured Speaker, 1995 Scholars Conference, University of Mississippi. Oxford, MS, October, 1995. Participant, Society of Environmental Toxicology and Chemistry Workshop on Whole- Effluent Toxicology. Pellston, MI, October, 1995. Invited Participant, Round Table Discussion of Surfactant Toxicity in Aquatic Systems. Thornton, England, May, 1996. Keynote Speaker, Mid-South Society of Environmental Toxicology and Chemistry (inaugural meeting). Memphis, TN, May, 1996. Invited Speaker on Endocrine Disruption, Seminar on Emerging Water Issues, International Paper Company. Memphis, TN, June, 1996. Instructor, Short Course on Constructed Wetlands, U.S. Army Waterways Experiment Station. Berkeley, CA. July, 1996. Short Course on Constructed Wetland Design and Monitoring. Houston, TX, July, 1996. Conference Organizer, Fourth International Conference on Transport, Fate and Effects of Silver in the Environment. Madison, WI, August, 1996. Friends of Lake Keowee (FOLKS), Board of Directors (elected) and Member of the Technical Committee, 2003-present. Bob C. Campbell Geology Museum, Clemson University, Board of Directors Member, 2003-present. Associate Editor, Journal of Toxicology and Environmental Health Part B : Critical Reviews. 1999-2006. Rodgers-24 Chair, Science Advisory Panel for the California Environmental Protection Agency - Aquatic Pesticides Committee, 2002-present. Member, Science Advisory Panel, USDA Jimmy Carter Plant Materials Center, Americus, GA. 2003-present. Member, Science Advisory Panel for the USEPA/ SETAC Whole Effluent Toxicity Testing Committee, 1998-2004. Member, Science Advisory Panel for Proposal and Research Review, Water Environment Federation, 2001-present. Member, Science Advisory Panel for the National Council for Air and Stream Improvement - Long Term Receiving Water Studies, 1999-present. Member, Board of Directors - Aquatic Plant Management Society, (elected) 2003-2006. Co-editor (with Dr. J.W. Castle), Special Issue of Environmental Geoscience on Constructed Wetland Treatment Systems BOOKS, BOOK CHAPTERS,AND MONOGRAPHS M.Sc. Thesis: Rodgers, J.H., Jr. 1974. Thermal Effects on Primary Productivity of Phytoplankton, Periphyton, and Macrophytes in Lake Keowee, S.C. Botany Department, Clemson University. 88 pp. Bi- weekly in situ determinations of Carbon-14 assimilation rates were made using SCUBA and chambers in a reservoir receiving thermal effluent from a nuclear power plant. Emphasis was placed upon relative contributions of each group of plants to the overall lake productivity and statistical correlations of productivity with water temperatures (1972-1974). Ph.D. Dissertation: Rodgers, J.H., Jr.1977. Aufwuchs Communities of Lotic Systems: Nontaxonomic Structure and Function. Biology Department and Center for Environmental Studies, VPI&SU. 336 pp. Six model streams were constructed to assess effects of typical industrial and municipal effluents on primary productivity, assimilatory sulfate reduction and structural aspects of assemblages of attached microorganisms. Net microbial productivity of aufwuchs and Rodgers-25 primary productivity were estimated by assimilatory (S35) sulfate reduction and carbon- 14 fixation, respectively, with heterotrophic productivity being the difference. Concurrent laboratory studies verified the efficacy of these procedures. The ability of methods to discern perturbations was tested. Direct correlations between structural measurements and functions were ascertained by regression analysis. Field investigations of aufwuchs communities were inconclusive due to variability and the heterogeneous distribution of aufwuchs communities (1974 - 1977). Guthrie, R.K., D.S. Cherry, and J.H. Rodgers, Jr. 1974. The Impact of Ash Basin Effluent on Biota in the Drainage System. Proc. Seventh Mid-Atlantic Industrial Waste Conference: pp. 17-43. Drexel University, Philadelphia, Pa. Dickson, K.L., J. Cairns, Jr., J.R. Clark and J.H. Rodgers, Jr. 1978. Evaluating Pollution Stress on Ecosystems. In: K.C. Flynn and W.T. Mason (eds.) The Freshwater Potomac - Aquatic Communities and Environmental Stress. The Interstate Commission on the Potomas River Basin, Rockville, Maryland. pp. 80 - 83. Rodgers, J.H., Jr., D.S. Cherry, K.L. Dickson, and J. Cairns, Jr. 1979. Invasion, Population Dynamics and Elemental Accumulation of Corbicula fluminea in the New River at Glen Lyn, Virginia. In: Proc. First International Corbicula Symposium J.C. Britton (ed.). Texas Christian University Research Foundation Publishers, Fort Worth, TX, pp. 99-110. Rodgers, J.H., Jr., K.L. Dickson, and J. Cairns, Jr. 1979. A Review and Analysis of Some Methods Used to Measure Functional Aspects of Periphyton. In: R.L. Weitzel (ed.) Methods and Measurements ofPeriphyton Communities:Review. American Society for Testing and Materials, Philadelphia, Pennsylvania (ASTM STP 690), pp. 142-167. Rodgers, J.H., Jr., D.S. Cherry, R.L. Graney, K.L. Dickson, and J. Cairns, Jr. 1980. Comparison of Heavy Metal Interactions in Acute and Artificial Stream Bioassay Techniques for the Asiatic Clam (Corbicula fluminea). In: J.G. Eaton, P.R. Parish, and A.C. Hendricks (eds.) Aquatic Toxicology. American Society for Testing and Materials, Philadelphia, PA. (ASTM STP 707), pp. 266-280. Cherry, D.S., J.H. Rodgers, Jr., R.L. Graney, and J. Cairns, Jr. 1980. Dynamics and Control of the Asiatic Clam in the New River, Virginia. Bulletin 123, Virginia Water Resources Research Center. Virginia Polytechnic Institute and State University, Blackburg, VA. 72 pp. Dillon, C.R. and J.H. Rodgers, Jr. 1980. Thermal Effects on Primary Productivity of Phytoplankton. Periphyton. and Macrophytes in Lake Keowee. S.C. Technical Report No. 81, Clemson University Water Resources Research Institute, Clemson, S.C. 115 PP. Rodgers-26 Rodgers, J.H., Jr., J.R. Clark, K.L. Dickson, and J. Cairns, Jr. 1980. Nontaxonomic analyses of structure and function of aufwuchs communities in lotic microcosms. In: J.P. Geisy, Jr. (ed.). Microcosms in Ecological Research. USDOE (CONF-781101) pp. 625-643. Lee, C.M., H. Bergman, W. Wood, and J.H. Rodgers, Jr. 1982. Workshop Summary and Conclusions. In: K.L. Dickson, A.W. Maki and J. Cairns, Jr. (eds.) Modeling the Fate of Chemicals in the Aquatic Environment, Ann Arbor: Ann Arbor Science Publ. pp. 397-407. Cairns, J., Jr., A.L. Buikema, Jr., D.S. Cherry, E.E. Herricks, R.A. Matthews, B.R. Neiderlahner, J.H. Rodgers, Jr. and W.H. Van der Schalie. 1982. Biological Monitoring in Water Pollution. Pergamon Press: New York. 116 pp. Rodgers, J.H., Jr., M.E. McKevitt, D.O. Hammerland, K.L. Dickson and J. Cairns, Jr. 1983. Primary production and decomposition of submergent and emergent aquatic plants of two Appalachian rivers. In: T.D. Fontaine III and S.M. Bartell (eds.) Dynamics of Lotic Ecosystems. Ann Arbor Science Publ. pp. 298-301. Staples, C.A., K.L. Dickson, F.Y. Saleh, and J.H. Rodgers, Jr. 1983. A microcosm study of lindane and naphthalene partitioning for model validation. In: W. Bishop, R.D. Caldwell, and B.B. Heidolph (eds.) Aquatic Toxicology and Hazard Assessment. STP 802 ASTM Publications, Philadelphia, PA. pp. 26-41. Rodgers, J.H., Jr. K.L. Dickson, and M.J. Defoer. 1983. Bioconcentration of lindane and naphthalene in bluegills (Lepomis macrochirus). In: W. Bishop, R.D. Cardwell, and B.B. Heidolph (eds.) Aquatic Toxicology and Hazard Assessment. STP 802. ASTM Publications, Philadelphia, PA. pp. 300-311. Saleh, F.Y., K.L. Dickson, and J.H. Rodgers, Jr. 1984. Transport Processes of Naphthalene in the Aquatic Environment. In: L. Pawlowski, A.J. Verdier, and W.J. Lacy (eds.) Chemistry for Environmental Protection. Elsevier Publisher. pp. 119-131. Vance, B.D. and J.H. Rodgers, Jr. 1984. General Botany, 2nd Ed. Hunter Textbooks, Inc., Winston - Salem, NC. 93 pp. Staples, C.A., K.L. Dickson, J.H. Rodgers, Jr., and F.Y. Saleh. 1985. A Model for Predicting the Influence of Suspended Sediments on Bioavailability of Neutral Organics in the Water Compartment. In: R.D. Cardwell, R.C. Bahner and R.E. Purdy (eds.) Aquatic Toxicology and Hazard Assessment. ASTM STP 845, ASTM Philadelphia, PA. pp. 417-428. Dickson, K.L. and J.H. Rodgers, Jr. 1985. Assessing the Hazards of Effluents in the Rodgers-27 Aquatic Environment. In: H. Bergman, A. Maki and R. Kimerle (eds.) Assessing the Hazards of Effluents to Aquatic Life. Pergamon Press. Rodgers, J.H., Jr., K.L. Dickson, F.Y. Saleh, and C.A. Staples. 1987. Bioavailability of Sediment-bound Chemicals to Aquatic Organisms; Some Theory, Evidence and Research Needs. In: K.L. Dickson, A.W. Maki and W.A. Brungs (eds.) Fate and Effects of Sediment-Bound Chemicals in Aquatic Systems. Pergamon: Elmsford, N.Y. pp. 245- 266. Anderson, J., W. Birge, J. Gentile, J. Lake, J.H. Rodgers, Jr. and R. Swartz. 1987. Biological Effects, Bioaccumulation, and Ecotoxicology of Sediment-associated Chemicals. In: K.L. Dickson, A.W. Maki, and W.A. Brungs (eds.) Fate and Effects of Sediment-Bound Chemicals in Aquatic Systems. Pergamon: Elmsford, N.Y. pp. 267- 296. Rodgers, J.H. Jr., P.A. Clifford and R.M. Stewart. 1991. Enhancement of HERBICIDE, the Aquatic Herbicide Fate and Effects Model. In: Proceedings, 25th Annual Meeting, Aquatic Plant Control Research Program. Misc. Paper A-91-3. pp. 279-282. U.S. Army Engineer Waterways Experiment Station, Vicksburg, MS. Rodgers, J.H. Jr. 1991. Herbicide Registration for Aquatic Use: A Look to the Future. In: Proceedings, 25th Annual Meeting, Aquatic Plant Control Research Program. Misc. Paper A-91-3. pp. 245-248. U.S. Army Engineer Waterways Experiment Station, Vicksburg, MS. Graney, R.L., J.H. Kennedy and J.H. Rodgers, Jr. (eds.). 1993. Aquatic Mesocosm Studies in Ecological Risk Assessment. Lewis Publishers, Baca Raton, FL. 723 pp. Rodgers, J.H., Jr., A.W. Dunn and A.B. Jones. 1993. Triclopyr Concentrations in Eurasian Watermilfoil: Uptake Under Differing Exposure Scenarios. In: Proceedings, 28th Annual Meeting, Aquatic Plant Control Research Program. Misc. Paper A-94-2. pp. 249-259. U.S. Army Waterways Experiment Station, Baltimore, MD. November 15-18, 1993. Rodgers, J.H., Jr. and A.W. Dunn. 1994. TVA - Guntersville Reservoir Herbicide Monitoring Survey 1991-1992. A Report to the Tennessee Valley Authority and U.S. Army Corps of Engineers Joint Agency Program. 116 p. Solomon, K., D. Bright, P. Hodson, K.-J. Lehtinen, B. McKague and J. Rodgers, Jr. 1999. Evaluation of ecological risks associated with the use of chlorine dioxide for the bleaching of pulp. Report prepared for the Alliance for Environmental Technology. 86 PP. Rodgers, J.H., Jr. and J.F. Thomas. 2004. Evaluations of the Fate and Effects of Pulp Rodgers-28 and Paper Mill Effluents from a Watershed Multistressor Perspective: Progress to Date and Future Opportunities. In: Pulp and Paper Mill Effluent Environmental Fate and Effects. D. L. Borton, T. J. Hall, R.P. Fisher, and J.F. Thomas (eds.). DEStech Publications, Lancaster, PA. pp.135-146. PAPERS AND PUBLICATIONS: Rodgers, J.H., Jr., G.L. Powell, and J.F. Geldard. 1973. Triple-label Liquid Scintillation Radioassay: Possible or Impossible? Seventh Annual Regional Meeting (Oct. 5) Wilmington, N.C. 43 pp. Rodgers, J.H., Jr. and R.S. Harvey. 1976. The Effect of Current on Periphyton Productivity Determined Using Carbon-14. Water Res. Bull. 12(6): 1109-1118. Cherry, D.S., R.K. Guthrie, J.H. Rodgers, Jr., K.L. Dickson, and J. Cairns, Jr. 1976. Responses of Mosquito Fish (Gambusia affinis) to Ash Effluent and Thermal Stress. Trans. Am. Fish Soc. 105(6):686-694. Rodgers, J.H., Jr., D.S. Cherry, J.R. Clark, K.L. Dickson, and J. Cairns, Jr. 1977. The Invasion of Asiatic Clam, Corbicula manilensis (Philippi), in the New River, Virginia. The Nautilus 91(2):43-46. Rodgers, J.H., Jr., D.S. Cherry, and R.K. Guthrie. 1978. Cycling of Elements in Duckweed (Lemna perpusilla Torrey) of an Ash Settling Basin and Swamp Drainage System. Water Research 12:765-770. Rodgers, J.H., Jr., K.L. Dickson, and J. Cairns, Jr. 1978. A Chamber for In Situ Measurement of Primary Productivity and Other Functional Processes of Periphyton in Lotic Systems. Arch. Hydrobiol. 84(3):389-398. Clark, J.R., J.H. Rodgers, Jr., K.L. Dickson, and J. Cairns, Jr. 1980. Using Artificial Streams to Evaluate Perturbation Effects on Aufwuchs Structure and Function. Water Res. Bull. 16(1):100-104. Graney, R.L., D.S. Cherry, J.H. Rodgers, Jr., and J. Cairns. 1982. The Influence of Thermal Discharges and Substrate Composition on the Population Structure and Distribution of the Asiatic Clam, Corbicula fluminea, in the New River, Virginia. The Nautilus 94(4):130-135. Matthews, R.A., A.L. Buikema, J. Cairns, Jr. and J.H. Rodgers, Jr. 1982. Biological Rodgers-29 Monitoring Part IIA Receiving System Functional Methods, Relationships and Indices. Water Res. 16:129-139. Saleh, F.Y., K.L. Dickson, and J.H. Rodgers, Jr. 1982. Fate of Lindane in the Aquatic Environment: Rate Constants of Physical and Chemical Processes. Environ. Toxicol. Chem. 1:289-297. Dickson, K.L. and J.H. Rodgers, Jr. 1982. Assessing the Hazards of Effluents in the Aquatic Environment. In: H.L. Bergman, R.A. Kimerle and A.W. Maki (eds.) Environmental Hazard Assessment of Effluents. New York: Pergamon Press. Rodgers, J.H., Jr., K.L. Dickson, F.Y. Saleh, and C.A. Staples. 1983. Use of Microcosms to Study Transport, Transformation and Fate of Organics in Aquatic Systems. Environ. Toxicol. Chem. 2:155-167. Reinert, K.H. and J.H. Rodgers, Jr. 1984. Influence of Sediment Types on the Sorption of Endothall. Bulletin of Environmental Contamination and Toxicology. 32:557-564. Rodgers, J.H., Jr., K.H. Reinert, and M.L. Hinman. 1984. Water Quality Monitoring in Conjunction with the Pat Mayse Lake Aquatic Plant Management Program. In: Proceedings, 18th Annual Meeting, Aquatic Plant Control Research Program. November 14-17, 1983. Raleigh, NC. U.S. Army Corps of Engineers. Misc. Paper A-84- 4. pp. 17-24. Reinert, K.H., S. Stewart, M.L. Hinman, J.H.Rodgers, Jr., and T.J. Leslie. 1985. Release of Endothall from AQUATHOL GRANULAR AQUATIC HERBICIDE. Water Research 19:805-808. Reinert, K.H., J.H. Rodgers, Jr., M.L. Hinman, and T.J. Leslie. 1985. Compartmentalization and Persistance of Endothall in Experimental Pools. Ecotoxicology and Environmental Safety 10:86-96. Reinert, K.H., J.H. Rodgers, Jr., T.J. Leslie, and M.L. Hinman. 1986. Static Shake- Flask Biotransformation of Endothall. Water Research. 20:255-258. Reinert, K.H. and J.H. Rodgers, Jr. 1984 Using and Aquatic Herbicide (Endothall). 5:449-461. Validation Trial of Predictive Fate Models Environmental Toxicology and Chemistry Saleh, F.Y., K.L. Dickson, J.H. Rodgers, Jr. and C.A. Staples. 1985. Fate of Naphthalene in the Aquatic Environment. Environmental Toxicology and Chemistry 6: 449-461. Jop, K.M., J.H. Rodgers, Jr., P.B. Dorn and K.L. Dickson. 1985. Use of Hexavalent Rodgers-30 Chromium as a Reference Toxicant in Aquatic Toxicity Tests. In Tim Poston and R. Purdy (eds.) Aquatic Toxicology and Environmental Fate ASTM STP 921, American Society for Testing and Materials, pp. 390-403. Dorn, P.B., J.H. Rodgers, Jr., K.M. Jop, J.C. Raia and K.L. Dickson. 1987. Hexavalent Chromium as a Reference Toxicant in Effluent Toxicity Tests. Environmental Toxicology and Chemistry 6:435-444. Reinert, K.H., P.M. Rocchio, and J.H. Rodgers, Jr. 1986. Parameterization of Predictive Fate Models: A Case Study. Environmental Toxicology and Chemistry 6:99-104. Jop, K.M., J.H. Rodgers, Jr. E.E. Price, and K.L. Dickson. 1986. Renewal Device for Test Solutions in Daphnia Toxicity Tests. Bull. Environ. Contam. Toxicol. 36: 95-100. Hall, W.S., K.L. Dickson, F.Y. Saleh, J.H. Rodgers, Jr., D. Wilcox and A. Entazami. 1986. Effects of Suspended Solids on the Acute Toxicity of Zinc to Daphnia magna and Pimephales promelas. Water Res. Bull. 22(6):913-920. Jop, K.M., T.F. Parkerton, J.H. Rodgers, Jr., K.L. Dickson, and P.B. Dorn. 1987. Comparative Toxicity and Speciation of Two Hexavalent Chromium Salts in Acute Toxicity Tests. Environ. Toxicol. and Chem. 6:697-703. Hall, W.S., K.L. Dickson, F.Y. Saleh and J.H. Rodgers, Jr. 1986. Effects of Suspended Solids on the Bioavailability of Chlordane To Daphnia magna. Arch. Environ. Contam. Toxicol. 15:529-534. Fisher, F.M., K.L. Dickson, J.H. Rodgers, Jr., K. Anderson and J. Slocomb. 1988. A Statistical Approach to Assess Factors Affecting Water Chemistry Using Monitoring Data. Wat. Res. Bull. 24:1017-1026. Dorn, P.B. and J.H. Rodgers, Jr., 1990. Variability associated with identification of toxics in NPDES effluent toxicity tests. Environ. Toxicol. and Chem. 8: 893-902. Reinert, K.H. and J.H. Rodgers, Jr. 1987. Fate and persistence of aquatic herbicides. Reviews of Environmental Contamination and Toxicology 98:61-98. Reinert, K.H., M.L. Hinman, and J. H. Rodgers, Jr. 1988. Fate of Endothall During the Pat Mayse Lake (Texas) Aquatic Plant Management Program. Archives of Environmental Contamination and Toxicology 17:195-199. Davis, T.M., B.D. Vance, and J.H. Rodgers, Jr. 1988. Productivity Responses of Periphyton and Phytoplankton to Bleach-kraft Mill Effluent. Aquatic Toxicology 12:83- 106. Rodgers-31 Rodgers, J.H., Jr., P.A. Clifford, and R. M.Stewart. 1988. Development of A Coupled Herbicide Fate and Target Plant Species Effects Model (FATE). Proceedings, 22nd Annual Meeting, Aquatic Plant Control Research Program. Parkerton, T.F., S.M. Stewart, K.L. Dickson, J.H. Rodgers, Jr., and F.Y. Saleh. 1988. Evaluation of the Indicator Species Procedure for Deriving Site-Specific Water Quality Criteria for Zinc. Aquatic Toxicol and Hazard Assess.: 10th Vol, ASTM STP 971. Philadelphia. pp. 423-435. Cassidy, K. and J.H. Rodgers, Jr. 1988. Response of Hydrilla (Hydrilla verticillata (L.f.) Royle) to Diquat and a Model of Uptake Under Nonequilibrium Conditions. Environ. Toxicol. Chem. 8:133-140. Price, E.E., M.J. Donahue, K.L. Dickson and J.H. Rodgers, Jr. 1990. Effects of Elevated Calcium Concentration on Na-K-ATPase Activity in Two Euryhaline Species, Cyprinodon variegatus and Mysidopsis bahia. Bull. Environ. Contam. Toxicol. 44:121- 128. Rodgers, J.H., Jr. and A.W. Dunn. 1992. Developing Design Guidelines for Constructed Wetlands to Remove Pesticides from Agricultural Runoff. Ecol. Engineering 1:83-95. Suedel, B.C. and J.H. Rodgers, Jr. 1991. Variability of Bottom Sediment Characteristics of the Continental United States. Water Res. Bull. 27:101-109. Suedel, B.C., J.H. Rodgers, Jr. and P.A. Clifford. 1993. Bioavailability of Fluoranthene in Freshwater Sediment Toxicity Tests. Environ. Toxicol. Chem. 12:155-165. Meyer, C.L., B.C. Suedel, J.H. Rodgers, Jr. and P.B. Dorn. 1993. Bioavailability of Sediment-sorbed Chlorinated Ethers. Environ. Toxicol. Chem. 12:493-505. Suedel, B.C. and J.H. Rodgers, Jr. 1994. Development of Formulated Reference Sediments for Freshwater and Estuarine Sediment Testing. Environ. Toxicol. Chem. 13(7):1163-1175. Suedel, B.C. and J.H. Rodgers, Jr. 1994. Responses of Hyalella azteca and Chironomus tentans to Particle Size Distribution and Organic Matter Content of Formulated and Natural Freshwater Sediments. Environ. Toxicol. Chem. 13(10):1639- 1648. Suedel, B.C., E. Deaver and J.H. Rodgers, Jr. 1995. Experimental Factors That May Affect Toxicity of Aqueous and Sediment-Bound Copper to Freshwater Organisms. Arch. Environ. Contam. Toxicol. 30(1):40-46. Suedel, B.C., E. Deaver and J.H. Rodgers, Jr. 1995. Formulated Sediment as a Rodgers-32 Reference and Dilution Sediment in Definitive Toxicity Tests. Arch. Environ. Contam. Toxicol. 30(1):47-52. Kline, E.R., R.A. Figueroa, J.H. Rodgers, Jr. and P.B. Dorn. 1996. Effects of a Nonionic Surfactant (C14.15 AE-7) on Fish Survival, Growth and Reproduction in the Laboratory and in Outdoor Stream Mesocosms. Environ. Toxicol. Chem. 15(6):997-1002. Rodgers, J.H., Jr., N.O. Crossland, E.R. Kline, W.B. Gillespie, Jr., R.A. Figueroa and P.B. Dorn. 1996. Design and Construction of Model Stream Ecosystems. Ecotoxicol. and Environ. Safety 33:30-37. Suedel, B.C., E. Deaver and J.H. Rodgers, Jr. 1996. Environmental Factors That May Affect Toxicity of Aqueous and Sediment-Bound Copper to Freshwater Organisms. Arch. Environ. Contam. and Toxicol. 30:40-46. Suedel, B.C. and J.H. Rodgers, Jr. 1996. Toxicity of Fluoranthene to Daphnia magna, Hyalella azteca, Chironomus tentans and Stylaria lacustris in Water-Only and Whole Sediment Exposures. Bull. Environ. Contam. Toxicol. 57:132-138. Rodgers, J.H., Jr., E. Deaver, B.C. Suedel and P.L. Rogers. 1997. Comparative Aqueous Toxicity of Silver Compounds: Laboratory Studies With Freshwater Species. Bull. Environ. Contam. and Toxicol. 58 (6): 851-858. Hawkins, W.B., J.H. Rodgers, Jr., W.B. Gillespie, Jr., A.W. Dunn, P.B. Dorn and M.L. Cano.1997. Design and Construction of Wetlands for Aqueous Transfers and Transformations of Selected Metals. Ecotoxicol. And Environ. Safety 36: 238-248. Gillespie, W.B., Jr., J.H. Rodgers, Jr., and N.O. Crossland. 1996. Effects of a Nonionic Surfactant (C14-15 AE-7) on Aquatic Invertebrates in Outdoor Stream Mesocosms. Environ. Toxicol. Chem. 15(8): 1412-1422. Gillespie, W.B., Jr., J.H. Rodgers, Jr., and P.B. Dorn. 1997. Responses of Aquatic Invertebrates to a C9_11 Linear Alcohol Ethoxylate Surfactant in Outdoor Stream Mesocosms. AquaticToxicol. 37: 221-236. Gillespie, W.B., Jr., J.H. Rodgers, Jr. and P.B. Dorn. 1996. Responses of Aquatic Invertebrates to a Linear Alcohol Ethoxylate Surfactant in Stream Mesocosms. Ecotoxicol. 41: 215-221. Dorn, P.B., J.H. Rodgers, Jr., W.B. Gillespie, Jr., R.E. Lizotte, Jr. and A. W. Dunn. 1997. The effects of a C12-13 linear alcohol ethoxylate surfactant on periphyton, macrophytes, invertebrates and fish in stream mesocosms. Environmental Toxicology and Chemistry 16(8): 1634-1645. Rodgers-33 Harrelson, R.A., J.H. Rodgers, Jr., W.B. Gillespie, Jr., A.W. Dunn, P.B. Dorn and M.L. Cano. 1997. Responses of fish exposed to a C9-11 linear alcohol ethoxylate nonionic surfactant in stream mesocosms. Ecotoxicology 6: 321-333. Hawkins, W.B., J.H. Rodgers, Jr., W.B. Gillespie, Jr., A.W. Dunn, P.B. Dorn and M.L. Cano. 1997. Desgn and construction of wetlands for aqueous transfers and transformations of selected metals. Ecotoxicology and Environmental Safety 36: 238- 248. Rodgers, J.H., Jr., E. Deaver, B.C. Suedel and P.L. Rogers. 1997. Comparative aqueous toxicity of silver compounds: Laboratory studies with freshwater species. Bulletin of Environmental Contamination and Toxicology 58(6) 851-858. Chapman, P.M., B. Anderson, S. Carr, V. Engles, R. Green, J. Hameedi, M. Harmon, P. Haverland, J. Hyland, C. Ingersoll, E. Long, J. Rodgers, Jr., M. Salazar, P.K. Sibley, P.J. Smith, R.C. Smith, B. Thompson and H. Windom. 1997. General guidelines for using the Sediment Quality Triad. Marine Pollution Bulletin 34(6): 368-372. Moore, M.T., D.B. Huggett, W.B. Gillespie, Jr., J.H. Rodgers, Jr., and C.M. Cooper. 1998. Comparative toxicology of chlordane, chlorpyrifos, and aldicarb to four aquatic testing organisms. Archives of Environmental Contamination and Toxicology 34: 152- 157. Gillespie, W.B., Jr., J.H. Rodgers, Jr. and P.B. Dorn. 1998. Responses of aquatic invertebrates to linear alcohol ethoxylate surfactant in stream mesocosms. Ecotoxicology and Environmental Safety 41: 215-221. Solomon, K., D. Bright, P. Hudson, K.-J Lehtinen, B. McKague and J. H. Rodgers. 1999. Evaluation of ecological risks associated with the use of chlorine dioxide for the bleaching of pulp. Report prepared for the Alliance for Environmental Technology. 86pp. Rodgers, J.H., Jr. 1999. Editorial-Opportunities and challenges for SETAC in the next century. Environmental Toxicology and Chemistry 18(11): 2401-2402. Moore, M.T., D.B. Huggett, G.M. Huddleston III, J.H. Rodgers, Jr. and C.M. Cooper. 1999. Herbicide effects on Typha latifolia (Linneaus) germination and root and shoot development. Chemosphere. 38 (15): 3637-3647. Lizotte, R.W., Jr., D.C.L. Wong, P.B. Dorn, and J.H. Rodgers, Jr. 1999. Effects of a homologous series of linear alcohol ethoxylate surfactants on fathead minnow early life stages. Archives of Environmental Contamination and Toxicology 37: 536-541. Huggett, D.B., Gillespie, Jr. and J. H. Rodgers, Jr. 1999. Copper bioavailability in Steilacoom Lake sediments. Archives of Environmental Contamination and Toxicology Rodgers-34 36: 120-123. Gillespie, W.B., Jr. W.B. Hawkins, J.H. Rodgers, Jr., M.L. Cano and P.B. Dorn. 1999. Transfers and transformations of zinc in flow-through wetland microcosms. Ecotoxicology and Environmental Safety 43: 126-132. Goodfellow, W.L., L.W. Ausley, D.T. Burton, D.L. Denton, P.B. Dorn, D.R. Grothe, M.A. Heber, T.J. Norberg-King and J. H. Rodgers, Jr. 2000. Major ion toxicity in effluents: A review with permitting recommendations. Environmental Toxicology and Chemistry 19(1): 175-182. Gillespie, W.B., Jr., W.B. Hawkins, J.H. Rodgers, Jr., M.L. Cano, and P.B. Dorn. 2000. Transfers and transformations of zinc in constructed wetlands: Mitigation of a refinery effluent. Ecological Engineering 14: 279-292. Mastin, B.J. and J.H. Rodgers, Jr. 2000. Toxicity and bioavailability of copper herbicides (Clearigate, Cutrine-Plus, and copper sulfate) to freshwater animals. Arch. Environ. Contam. Toxicol. 39: 445-451. D'Surney, S.J., L.P. Eddy, D.P. Felder, J.H. Rodgers,Jr., and T.L. Deardorff. 2000. Assessment of the Impact of a Bleached Kraft Mill Effluent on a South-Central USA River. Environmental Toxicology 15(1): 28-39. Huddleston, III, G.M., W.B. Gillespie, Jr., and J.H. Rodgers, Jr. 2000. Using Constructed Wetlands to Treat Biochemical Oxygen Demand and Ammonia Associated with a Refinery Effluent. Ecotoxicology and Environmental Safety 45: 188-193. Moore, M.T., J.H. Rodgers, Jr., C.M. Cooper and S. Smith, Jr. 2000. Constructed wetland for mitigation of atrazine-associated agricultural runoff. Environmental Pollution 110: 393 - 399. Lehman, R. and J.H. Rodgers, Jr. 2000. It's not that easy being green. Water, Environment and Technology (March, 2000) 54-59. Moore, M.T., J.H. Rodgers, Jr., S. Smith, Jr. and C.M. Cooper. 2001. Mitigation of metolachlor-associated agricultural runoff using constructed wetlands in Mississippi, USA. Agriculture, Ecosystems and Environment 84: 169 - 176. Mastin, B.J., R. M. Sherrard, J.H. Rodgers, Jr. and Y.T. Shah. 2001. Hybrid cavitation/ constructed wetland reactors for treatment of chlorinated and non-chlorinated organics. Chemical Engineering Tech 24(8): 97A-105A. Winfield, L.E., D'Surney, S.J., and Rodgers, J.H., Jr. 2001. The response of terrestrial plants to short-term hexahydro-1,3,5-trinitro-1,3,5-triazine (RDX) exposure. In Rodgers-35 Proceedings, Conference on Sustainability of Wetlands and Water Resources. Center for Water and Wetland Resources at the Univ. of MS Biology Field Station. University, MS. Mastin, B.J., J.H. Rodgers, Jr. and T.L. Deardorff. 2002. Risk evaluation of cyanobacteria-dominated algal blooms in a North Louisiana reservoir. J Aquat Ecosyst Stress Recov. 9: 103-114. Sherrard, R.M. C.L. Murray-Gulde, J.H. Rodgers, Jr. and Y.T. Shah. 2002. Comparative toxicity of chlorothalonil and chlorpyrifos: Ceriodaphnia dubia and Pimephales promelas. Environ. Toxicol. 17(6): 503-512. Lizotte, R., P. Dorn, R.W. Steireide, D.C.L. Wong,and J.H. Rodgers, Jr. 2002. Ecological effects of an anionic C12-15 alkylethoxy sulfate surfactant in outdoor stream mesocosms. Environ. Toxicol. Chem. 21(12): 2742-2751. Moore, M.T., R. Schulz, C.M. Cooper, S, Smith, Jr. and J.H. Rodgers, Jr. 2002. Mitigation of chloropyrifos runoff using constructed wetlands. Chemosphere 46: 827- 835. Murray-Gulde, C.L., J.E. Heatley, A.L. Schwartzman and J.H. Rodgers, Jr. 2002. Algicidal effectiveness of Clearigate, Cutrine-Plus and copper sulfate and margins of safety associated with their use. Arch Environ Contam Toxicol 43(1): 19-27. Murray-Guide, C.L., J.E. Heatley, T. Karanfil and J.H. Rodgers, Jr. 2003. Performance of a hybrid reverse osmosis - constructed wetland treatment system for brackish produced water. Water Research 37: 705-713. Murray-Gulde, CL, Heatley JE, Karanfil T, Rodgers JH, Jr. 2003. Performance of a Hybrid Reverse Osmosis-Constructed Wetland Treatment System for Brackish Produced Water. Water Research 37:705-713. Sherrard, R.M., C.L. Murray-Gulde, J.H. Rodgers, Jr. and Y.T. Shah. 2003. Comparative toxicology of Chlorothalonil: Ceriodaphnia dubia and Pimephales promelas. Ecotoxicology and Environmental Safety 56: 327-333. Winfield, L.E., Rodgers, J.H., Jr., and D'Surney, S.J. 2004. The responses of terrestrial plants to short (<12 days) and long term (2,4, and 6 weeks) hexahydro-1,3,5-trinitro- 1,3,5-triazine (RDX) exposure: Part I: Growth and development effects. Ecotoxicology 13: 335-347. Sherrard, R.M., J.S. Bearr, C.L. Murray-Gulde, J.H. Rodgers, Jr. and Y.T. Shah. 2004. Feasfibility of Constructed Wetlands for Removing Chlorothalonil and Chlorpyrifos from Aqueous Mixtures. Environmental Pollution 127: 385-394. Rodgers-36 Huddleston, G.M., J.H. Rodgers, Jr., C.L. Murray-Guide and F. D. Mooney. 2005. Designing constructed wetlands for mitigating risks from flue gas desulfurization wastewater. Proceedings of the Georgia Water Resources Conference, April 25-27. Univ. of Georgia, K.J. Hatcher (ed.) Institute of Ecology, The University of Georgia, Athens, GA. Murray-Gulde, C. L, Bearr, J. and Rodgers, Jr., J.H. 2005. Evaluation of a constructed wetland designed to decrease copper concentrations in a wastestream. Ecotoxicology and Environmental Safety 61:60-73. Murray-Gulde, G.M. Huddleston III, K.V. Garber and J.H. Rodgers, Jr. 2005. Contributions of Schoenoplectus californicus in a constructed wetland system receiving copper contaminated wastewater. Water, Air and Soil Pollution 163: 355-378. J.H. Rodgers, Jr., G.M. Huddleston III, C.L. Murray-Guide and F. D. Mooney. 2005. Designing constructed wetlands for mitigating risks from flue gas desulfurization wastewater. Proceedings of the International Water Conference, October, 2005. Orlando, FL. 7pp. Castle, J. W., Evan H. Cross, L. E. Kanagy, J. H. Rodgers, and B. M. Johnson. 2006. Management of produced waters from underground gas storage. GasTIPS. 12(4):11-13. Kanagy, L.E., B.M. Johnson, J.W. Castle, and J.H. Rodgers Jr. 2007. Design and performance of a pilot-scale constructed wetland treatment system for natural gas storage produced water. Bioresource Technology (In press). Castle, J.W. and J.H. Rodgers, Jr. 2008. Constructed wetlands treatment systems: Renovation of impaired waters for beneficial reuse. (Introduction: Special Issue 1) Environmental Geosciences 15(1): iv. Rodgers, J.H., Jr. and J.W. Castle. 2008. Constructed wetland systems for efficient and effective treatment of contaminated waters for reuse. Environmental Geosciences 15 (1): 1-8. Huddleston, G.M., and J.H. Rodgers, Jr. 2008. Design of a constructed wetland system for treatment of copper-contaminated wastewater. Environmental Geosciences 15(1): 9- 19. Murray- Guide, C., William Bridges and J.H. Rodgers, Jr. 2008. Evaluating performance of a constructed wetland treatment system designed to decrease bioavailable copper in a waste stream. Environmental Geosciences 15 (1): 21-38. Tedrow, O.R., B. M. Duke, W. Chao, L. Jolley, W. Frazier, and J H. Rodgers, Jr. (In Rodgers-37 review) Laboratory and field responses of Lyngbya sp. following exposures to copper- containing algaecides. Journal of Aquatic Plant Management. Eggert, D.A, J. H. Rodgers, Jr., G. M. Huddleston, and C. E. Hensman. (In review) Performance of Pilot-Scale Constructed Wetland Treatment Systems for Flue Gas Desulfurization (FGD) Waters. Environmental Geosciences. Johnson, B M., M.M. Chao, O.R. Tedrow, A.D. McQueen, and J.H. Rodgers, Jr. (In review). Responses of Lepomis macrochirus, Pimephales promelas, Hyalella azteca, Ceriodaphnia dubia, and Daphnia magna to Exposures of Algimycin° PWF and Copper Sulfate Pentahydrate. Journal of Aquatic Plant Management. Johnson, B. M., L. E. Kanagy, J. H. Rodgers Jr., J. W. Castle. (In review). Feasibility of a pilot-scale hybrid constructed wetland treatment system for simulated natural gas storage produced waters. Environmental Geoscience. Rodgers, J. H., and B. M. Johnson. 2007. Technical Fact Sheet on Lyngbya (Blue- Green Alga) Submitted to US Army Corps of Engineers, Waterways Experiment Station, Vicksburg, MS. Kenagy, L.E., B.M. Johnson, J.W. Castle and J. H. Rodgers, Jr. (in prep.) Pilot scale constructed wetland treatment systems for simulated natural gas storage produced waters: comparison of hydrosoil conditions and performance. PUBLISHED ABSTRACTS AND PRESENTATIONS: Rodgers, J.H., Jr., and C.R. Dillon. 1974. A Comparative Study of the Primary Productivity of Limnetic Phytoplankton, Periphyton, and Benthic Macrophytes in Lake Keowee, S.C. S.C. Academy of Science (March 28-30) Coker College. Hartsville, S.C. Rodgers, J.H., Jr., C.R. Dillon, and R.S. Harvey 1974. A Preliminary report on the Effects of Temperature Elevation and Current on Periphyton Production in Natural and Artificial Streams. S.C. Academy of Science (March 29-30) Coker College. Hartsville, S. C. Rodgers, J.H., Jr. and C.R. Dillon. 1974. Thermal Effects on Primary Productivity of Rodgers-38 Limnetic Phytoplankton, Periphyton, and Benthic Macrophytes. Assoc. Southeastern Biol. Bull. 21:78. Rodgers, J.H., Jr., C.R. Dillon, and R.S. Harvey. 1974. Effects of Current and Temperature Elevation on Periphyton Production in Natural and Artificial Streams. Assoc. Southeastern Biol. Bull. 21:79. Rodgers, J.H., Jr., D.S. Cherry, and R.K. Guthrie. 1975. Ash Basin Effluent Impact on the Aquatic Flora of a Stream and Swamp Drainage System. Assoc. Southeastern Biol. Bull. 22:76. Kuhn, D.L., J.H. Rodgers, Jr. and W.H. Yongue, Jr. 1975. The Production and Effects of Extracellular Products on Freshwater Microbial Communities. Assoc. Southeastern Biol. Bull. 22:61. Rodgers, J.H., Jr., K.L. Dickson and J. Cairns, Jr. 1976. Laboratory and Field Studies of Sulfur-35 Sulfate Assimilation by Periphytic Organisms. Assoc. Southeastern Biol.Bull. 25:30. Clark, J.R. and J.H. Rodgers, Jr. 1976. Laboratory studies of Peltoperla maria Nymph Feeding Rates and Efficiency. (Pelcoptera: Peltoperlidae). Assoc. Southeastern Biol. Bull. 25:30. Rodgers, J.H., Jr., K.L. Dickson, and J.Cairns, Jr. 1976. Primary Production and Degradation rates of Submergent and Emergent Macrophytes of the New River, Glen Lyn, Va. Assoc. Southeastern Biol. Bull. 23:91. Clark, J.R., J.H. Rodgers, Jr. and K.L. Dickson. 1976. Relative Sensitivities of Methods Used to Evaluate the Effects of Perturbation on Periphyton Communities. Assoc. Southeastern Biol. Bull. 23:50. Rodgers, J.H., Jr., J.R. Clark, K.L. Dickson, and J. Cairns, Jr. 1977. Primary Production and Decomposition of Submergent and Emergent Aquatic Vascular Plants of the New River, Glen Lyn, Virginia. North Am. Benthological Soc. (April 6-8) Roanoke, VA. p. 26. Clark, J.R., J.H. Rodgers, Jr., K.L. Dickson, and J. Cairns, Jr. 1977. Analyses of Aufwuchs Communities. Assoc. Southeastern Biol. Bull. 24:81. Rodgers, J.H., Jr., J.R. Clark, K.L. Dickson, and J. Cairns, Jr. 1977. Functional Responses of Aufwuchs Communities to Perturbations in Artificial Streams. 40th Annual Meeting Am. Soc. Limnol. Oceanogr. (June 20-23) East Lansing, Mich. Rodgers, J.H., Jr., D.S. Cherry, K.L. Dickson, and J. Cairns, Jr. 1978. Influence of Thermal Effluent on Population dynamics of Asiatic Clam (Corbicula manilensis) in the Rodgers-39 New River, Virginia (Mollusca: Bivalvia).Assoc. Southeastern Biol. Bull. 25:48. Clark, J.R., J.H. Rodgers, Jr., K.L. Dickson, and J. Cairns, Jr. 1978. A Benthic Diatometer for Use in Large Rivers. North Am. Benthological Soc. (May 10-12) Winnipeg, Manitoba, Canada, p.9. Graney, R.L., J.H. Rodgers, Jr., D.S. Cherry, K.L. Dickson, and J. Cairns, Jr. 1978. Heavy Metal Accumulation by the Asiatic Clam (Corbicula manilensis) from Field Collections and Laboratory Bioassays. VA. Academy of Science, VPI&SU, Blacksburg, VA. Rodgers, J.H., Jr., D.S. Cherry, R.L. Graney, K.L. Dickson, and J. Cairns, Jr. 1978. Comparison of Elemental Accumulation by the Asiatic Clam (Corbicula fluminea) from Thermal Influenced River Water and Laboratory Bioassays. American Society for Testing and Materials Symposium on Aquatic Toxicology. (Oct. 16-17) New Orleans, LA. Rodgers, J.H., Jr., J.R. Clark, K.L. Dickson, and J. Cairns, Jr. 1978. Nontaxonomic Analyses of Structure and Function of Aufwuchs Communities in Lotic Microcosms. SREL Symposium "Microcosms in Ecological Research." (Nov. 8-11, 1978) Augusta, GA. Dal Santo, D. and J.H. Rodgers, Jr. 1979. Bluegill (Lepomis macrochirus) Blood Enzymes as Indicators of Exposure to Sublethal Concentrations of Cadmium. Assoc. Southeastern Biol. Bull. 26:54. Wallace, L.J.D. and J.H. Rodgers, Jr. 1979. Periphyton Electron Transport System as an Indicator of Perturbation in the Watauga River, Tennessee. Assoc. Southeastern Biol. 26:54. Molloy, B.K. and J.H. Rodgers, Jr. 1979. Periphyton Respiration in the Watauga River, Tennessee: Impact of Industrial and Municipal Effluents. Assoc. Southeastern Biol. Bull. 26:55. Graney, R.L., D.S. Cherry, and J. Cairns, Jr. 1979. Behavioral and Lethal Responses of the Asiatic Clam (Corbicula fluminea) to Cu, Zn, Cu-Zn, and K exposures. Assoc. Southeastern Biol. Bull. 26:89. Dickson, K.L., F.Y. Saleh, and J.H., Rodgers, Jr., 1980. Determining Specific Chemical Waste Load Allocations to Aquatic Receiving Systems. 53rd Annual Conference of the Water Pollution Control Federation. (Sept. 28 - Oct.3) Las Vegas, NV. Rodgers, J.H., Jr., M.E. McKevitt, D.O. Hammerland, K.L. Dickson, and J. Cairns, Jr. 1980. Primary Production and Decomposition of Submergent and Emergent Aquatic Rodgers-40 Plants of Two Appalachian Rivers. Symposium on Dynamics of Lotic Ecosystems. Savannah River Ecology Laboratory (Oct. 19-22) Augusta, GA. Saleh, F.Y., K.L. Dickson, and J.H. Rodgers, Jr. 1980. Fate of Lindane in the Aquatic Environment: Rate Constants of Physical and Chemical Processes. Annual Meeting of the Society of Environmental Toxicology and Chemistry. (Nov. 23-25) Arlington, VA. Staples, C.A., K.L. Dickson, J.H. Rodgers, Jr. and F.Y. Saleh. 1981. A Microcosm Study of Lindane and Napthalene Partitioning for Model Validation. Presented at the 6th Symposium on Aquatic Toxicology. (Oct. 13-14) Kansas, City, MO. Rodgers, J.H., Jr., K.L. Dickson, F.Y. Saleh, and C.A. Staples. 1981. Use of Microcosms to Study Transport, Transformation, and Fate of Organics in Aquatic Systems. Annual Meeting of the Society of Environmental Toxicology and Chemistry. (Nov. 22-25) Arlington, VA. Rodgers, J.H., Jr., 1982. Comparison of Biotransformation Rates to Biodegradation Rates and Mineralization to C02. 82nd Annual Meeting of the American Society for Microbiology, (March 7-12), Atlanta, GA. Rodgers, J.H., Jr., K.L. Dickson, and T.J. Leslie. 1982 . Relationships of Biotransformation and Ultimate Biodegradation of Organics in Aquatic Conference on Environmental Sciences - Water. (June 28- July 2) New Hampton, N.H. Saleh, F.Y., K.L. Dickson, J.H. Rodgers, Jr. 1982. Physical and Chemical Transport Processes for Napthalene and Lindane in the Aquatic Environment. Annual Meeting of the American Chemical Society, Division, of Environmental Chemistry. (Vol. 22, No.l). Rodgers, J.H., Jr., K.L. Dickson, F.Y. Saleh, C.S. Staples, and T.J. Leslie. 1982. Biodegradation and Biotransformation in the Hazard Evaluation Process. Third Annual Meeting of the Society of Environmental Toxicology and Chemistry. (November 14-17) Washington, D.C. Leslie, T.J., M. Page, K.H. Reinert, C.K. Moses, J.H. Rodgers, Jr., K.L. Dickson, and M.L. Hinman. 1983. Biotransformation of Organic Chemicals - Factors Important in Test Design. 83rd Annual Meeting of The American Society for Microbiology. (March 6-9) New Orleans, LA. Reinert, K.H., and J.H. Rodgers, Jr. 1983. Influence of Sediment Types on the Sorption of Endothall. Texas Water Pollution Control Federation. (May 25-27) Fort Worth, TX. Rodgers, J.H., Jr. 1983. Overview of Systems Analysis in Environmental Impact Assessment, Fate and Effects of Radioactive Materials, Demonstration of Computer Based Decision Systems. Federal Energy Institute. (September 12-13) Cuernavaca, Rodgers-41 Morelos, Mexico. Rodgers, J.H., Jr., K.H. Reinert, and M.L. Hinman. 1983. Water quality Monitoring in conjunction with the Pat Mayse Lake Aquatic Plant Management Program. Presented at the U.S. Army Corps of Engineers 18th Annual Aquatic Plant Control and Research Meeting. (November 14-17) Raleigh, NC. Reinert, K.H., M.L. Hinman, J.H. Rodgers, Jr., and K.L. Dickson. 1984. Need for Feedback from Fate and Effects Studies of Herbicides in Integrated Aquatic Weed Management. Presented at the 24th Annual Meeting of the Weed Science Society of America. (February 8-10) Miami, FL. Hinman, M.L., K.H. Reinert, and J.H. Rodgers, Jr., 1984. The Use of Laboratory Tests, Microcosms, and Field Studies to Validate Environmental Fate Models. Presented at the 57th Annual conference of the Water Pollution Control Federation. (September 30- October 4) New Orleans, LA. Reinert, K.H., and J.H. Rodgers, Jr. 1984. An Approach for Validating Predictive Fate Models Using an Aquatic Herbicide, Endothall. Presented at the 5th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (November 4-7) Arlington, VA. Rodgers, J.H., Jr., K.L. Dickson, F. Saleh, D. Wilcox, C. Staples, and S. Hall. 1984. Assessing the Role of Suspended Solids in Regulating the Bioavailability of Chemicals. Presented at the 5th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (November 4-7) Arlington, VA. Dorn, P.B., J.C. Raia, A.B. Greak, J.H. Rodgers, Jr., K.M. Jop, K.L. Dickson, and P.M. Rocchio. 1984. The Use of Potassium Dichromate as a Reference Toxicant in Effluent Bioassay Evaluations. Presented at the 5th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (November 4-7) Arlington, VA. Rodgers, J.H., Jr., and K.H. Reinert. 1984. Effects of Endothall Used to Control Eurasian Watermilfoil in Pat Mayse Lake, Texas. Presented at the Annual Meeting of the Florida Aquatic Plant Management Society. (October 23-25) Plant City, FL. Reinert, K.H., and J.H. Rodgers, Jr. 1984. Fate of Endothall Used to Control Eurasian Watermilfoil in Pat Mayse Lake, Texas. Presented at the annual Meeting of the Florida Aquatic Plant Management Society. (October 23-25) Plant City, FL. Rodgers, J.H., Jr., and P.A. Clifford. 1984. Pat Mayse Lake, Texas, Aquatic Plant Management Program: Continuing Studies. Presented at the U.S. Army Corps of Engineers 19th annual Aquatic Plant Control and Research Meeting. (November 14-17) Raleigh, NC. Rodgers-42 Leslie, T.J., K.L. Dickson, and J.H.Rodgers, Jr. 1984. Effects of Suspended Solids on the Biotransformation Rate Kinetics of Anthracene in River Water. Sixth International Biodeterioration Symposium. (August 6-10) Washington, D.C. Jop, K.M., J.H. Rodgers, Jr., P.B. Dorn, and K.L. Dickson. 1985. Use of Hexavalent Chromium as a Reference Toxicant in Toxicity Testing. Presented at the Ninth Symposium on Aquatic Toxicology and Environmental Fate. American Society for Testing and Materals Meeting. (April 14-16) Philadelphia, PA. Dorn, P.B., K.M. Jop, J.H. Rodgers, Jr., and K.L. Dickson. 1985. Difficulties in Using Screening Bioassays for Effluent Toxicity Testing. Presented at the 6t" Annual Meeting of the Society of Environmental Toxicology and Chemistry. St. Louis, MO. Rodgers, J.H., Jr., P.A. Clifford, K.H. Reinert, and M.L. Hinman. 1985. Management of Myriophyllum spicatum using Endothall: The Pat Mayse Lake Experience. Presented at the 25th Annual Meeting of the Aquatic Plant Management Society. Vancouver, British Columbia, Canada. Reinert, K.H., P.M. Rocchio, and J.H. Rodgers, Jr. 1985. Parameterization of Predictive Fate Models: A Case Study. Presented at the 6th Annual Meeting of the Society of Environmental Toxicology and Chemistry, St. Louis, MO. Parkerton, T.F., S.S. Stewart, K.L. Dickson, J.H. Rodgers, Jr., and F.Y Saleh. 1986. Evaluation of the Indicator Species Procedure for Deriving Site Specific Water Quality Criteria for Zinc. American Society for Testing and Materials -Tenth Symposium on Aquatic Toxicology and Hazard Assessment. (May 1986) New Orleans, LA. Rodgers, J.H., T.F. Parkerton, E.E. Price, P.B. Dorn, and K.L. Dickson. 1986. Is Your Wastewater Really Toxic? - Assessing Sources of Variability in Bioassays. Presented at the 59th Annual Conference of The Water Pollution Control Federation. (October 1986) Los Angeles, CA. Parkerton, T.F., S.M. Stewart, K.L. Dickson, J.H. Rodgers, Jr., and F.Y. Saleh. 1986. Application of Acute Toxicity Data for Deriving Site Specific Water Quality Criteria for Zinc in Three Texas Waters. Presented at the 59th Annual Conference of the Water Pollution Control Federation. (October 1986) Los Angeles, CA. Price, E.E., J.H. Rodgers, Jr., K.L. Dickson, P.B. Dorn, and K. Jop. 1986. Influence of Ion Composition and Ionic Strength on Observed Effluent Toxicity. Presented at the 59th Annual Conference of the Water Pollution Control Federation. (October 1986) Los Angeles, CA. Clifford, P.A., and J.H. Rodgers, Jr. 1986. Regrowth of Myriophyllum spicatum L. Rodgers-43 Harvested to Several Depths in a Texas reservoir. Presented at the 26th Annual Meeting of the Aquatic Plant Management Society, Inc. (July 13-16) Sarasota, FL. Rocchio, P.M., and J.H. Rodgers, Jr. 1986. The Relative Effectiveness of 2,4-D and Endothall on Myriophyllum heterophyllum. Presented at the 26th Annual Meeting of the Aquatic Plant Management Society, Inc. (July 13-16) Sarasota, FL. Rodgers, J.H., Jr., D.L. Robinson, C.L. Missimer, and J.F. Hall. 1986. Proximate Oxygen Demand of Three Aquatic Macrophytes: Use in Management of Aquatic Systems. Presented at the 26th Annual Meeting of the Aquatic Plant Management Society, Inc. (July 13-16) Sarasota, FL. Rodgers, J.H., Jr., and P.B. Dorn. 1986. Variability Associated With Identification of Toxics in NPEDS Effluent Bioassays. Presented at the 7th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (November 2-5) Alexandria, VA. Rodgers, J.H., Jr., 1986. Efforts Toward Development of an Aquatic Plant Management Concept for Pat Mayse Lake, Texas. 21St Annual Meeting Aquatic Plant Control Research Program of the U.S. Army Corps of Engineers. (Nov, 17-21) Mobile, AL. Price, E.E., K.L. Dickson, and J.H. Rodgers, Jr. 1986. Effects of Excessive Calcium Concentration on (Na+ + K+) ATPase Activity of Two Euryhaline species, Cvorinondon variegatus and Mysidopsis bahia. Presented at the 7th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (November 2-5) Alexandria, VA. Rocchio, P.M., and J.H. Rodgers, Jr. 1987. The Fate and Effects of Diquat and 2,4-D Amine in Laboratory Aquatic Systems. Eighth Annual Meeting of the Society of Environmental Toxicology and Chemistry. (Nov. 9-12) Pensacola, FL. Parkerton, T.F., S.M. Stewart, K.L. Dickson, J.H. Rodgers, Jr., and F.Y Saleh. 1987. Derivation of Site Specific Criteria for Zinc: Implications for Wasteload Allocation. 8th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (Nov. 9-12) Pensacola, FL. Rodgers, J.H., Jr., and P.A. Clifford. 1987. A Coupled Herbicide Fate and Target Species' Effects Model. 22nd Annual Meeting of the Aquatic Plant Control Research Program of the U.S. Army Corps of Engineers. (Nov. 16-19) Portland, OR. Rodgers, J.H., Jr. 1987. Management of Aquatic Plants in Texas Reservoirs. Southwest Regional Meeting of the North American Lake Management Society (July 27-28) Austin, TX. Rodgers, J.H., Jr. 1987. Aquatic Plants as Sentinels of Environmental Health. 26tn Annual Meeting of the Society of Toxicology (Feb. 24-27) Washington, D.C. Rodgers-44 Hall, J.F. and J.H. Rodgers, Jr. 1987. Use of Environmental Fate Information in Selection of Herbicides for Aquatic Plant Management. 27th Annual Meeting of the Aquatic Plant Management Society. (July 12-15) Savannah, GA. Cassidy, K.M. and J.H. Rodgers, Jr. 1987. Relationship Between Tissue Burden and Response of Hydrilla to Diquat. 27th Annual Meeting of the Aquatic Plant Management Society. (July 12-15) Savannah, GA. (Fourth Place in APMS Student Paper Contest). Rocchio, P.M., and J.H. Rodgers, Jr. 1987. Comparative Study of the Fate and Effects of Diquat and 2,4-D. 27th Annual Meeting of the Aquatic Plant Management Society. (July 12-15) Savannah, GA. (Second Place in APMS Student Paper Contest). Clifford, P.A. and J.H. Rodgers, Jr. 1987. Application and Validation of the COE-WES HARVEST Model in Pat Mayse Lake. 27th Annual Meeting of the Aquatic Plant Management Society. (July 12-15) Savannah, GA. Hall, J.F., T.F. Parkerton, J.H. Rodgers, Jr., and K.L. Dickson. 1987. Strategies for the Development of Sediment Quality Criteria: An Overview. South Central Chapter Meeting of the Society of Environmental Toxicology and Chemistry. (May 6, 1987) Houston, TX. Dickson, K.L., J.H. Rodgers, Jr., T.M. Davis, M.E. McKevitt, D.P. Wilcox, and K.A. Anderson. 1987. Use of In Situ Primary Productivity and Color Bioassays to Assess Papermill Impacts. American Society of Limnology and Oceanography Annual Meeting. (January 15) Madison, WI. Rodgers, J.H., Jr., J.H. Kennedy, J.F. Hall and B.C. Suedel. 1988. Test Methods for Sediment Toxicity Using Freshwater organisms. The Coastal Society - Eleventh International Conference. (October 22-26) Boston, MA. Rodgers, J.H., Jr. and P.A. Clifford. 1988. Validation of a Coupled Herbicide Fate and Effects Model: HERBICIDE. 23rd Annual Meeting of the Aquatic Plant Control Research Program of the U.S. Army Corps of Engineers. (Nov, 16-17) West Palm Beach, FL. Suedel, B.C. and J.H. Rodgers, Jr. 1988. Sediment Characteristics as Potential Normalization Factors for the Bioavailability of Neutral Organic Compounds Sorbed to Sediments. Poster presented at the Ninth Annual Meeting of the Society of Environmental Toxicology and Chemistry. (November, 1988) Arlington, VA. Suedel, B.C. and J.H. Rodgers, Jr. 1989. Sediment Quality Mediation of the Toxicity of Neutral Organic Compounds. Poster presented at the American Society for Testing and Materials, 13th Symposium on Aquatic Toxicology and Risk Assessment. (April 1989) Atlanta, GA. Rodgers-45 Suedel, B.C., J.H. Rodgers, Jr. and P.A. Clifford. 1989. Use of Organic Carbon as a Normalization Factor for the Bioavailability of Neutral Organic Compounds Sorbed to Sediments. Poster presented at the Tenth Annual Meeting of the Society of Environmental Toxicology and Chemistry. (October, 1989) Toronto, Canada. Suedel, B.C. and J.H. Rodgers, Jr. 1990. Sediment Characteristics That May Influence Aquatic Plant Distributions in the United States. Platform presentation at the 30th Annual Meeting of the Aquatic Plant Management Society. (July 17) Mobile, AL. Suedel, B.C., J.H. Rodgers, Jr. and P.A. Clifford. 1990. Bioavailability of Fluoranthene in Freshwater Sediment Toxicity Tests. Platform presentation at the Eleventh Annual Meeting of the Society of Environmental Toxicology and Chemistry. (November, 1990) Arlington, VA. Rodgers, J.H., Jr. and P.A. Clifford. 1990. Effective use of Sonar-SRP in marginal treatments for control of Myriophyllum spicatum. Presented at the 30th Annual Meeting of the Aquatic Plant Management Society, Inc. (July 15-18) Mobile, AL. Rodgers, J.H., Jr. 1990. Research on Aquatic Plant Effects on Water Quality and Fish. Presented at the 9th Annual Meeting of the Mid-South Aquatic Plant Management Society, Inc. (October 24-26) Eufaula, AL. Hall, J.F. and J.H. Rodgers, Jr. 1990. Characterization of Toxicants in Contaminated Sediments. Presented at the Eleventh Annual Meeting of the Society of Environmental Toxicology and Chemistry. (November 11-15) Arlington, VA. Rodgers, J.H., Jr. and J. Ackerman. 1990. Regulatory Issues and Future Data Requirements for Herbicide Registration for Aquatic Use. Presented at the 25th Annual Meeting of the Aquatic Plant Control Research Program. U.S. Army Corps of Engineers. (November 26-30) Orlando, FL. Rodgers, J.H., Jr. 1990. Chemical Control Simulation for Aquatic Plant Management. Presented at the 25th Annual Meeting of the Aquatic Plant Control Research Program. U.S. Army Corps of Engineers. (November 26-30) Orlando, FL. Suedel, B.C. and J.H. Rodgers, Jr. 1991. Fluoranthene Partitioning and Toxicity to Hyalella azteca in Freshwater Sediments. Presented at the 12th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (November, 1991) Seattle, WA. Giddings, J., J.H. Rodgers, Jr., R. Graney, T. La Point, R. Meyerhoff, S. Orenstein, and L. Touart. 1991. Conclusions of the SETAC Workshop on Microcosms for Ecological Assessment of Pesticides. Presented at the 12th Annual Meeting of the Society for Environmental Toxicology and Chemistry. (November, 1991) Seattle, WA. Rodgers-46 Rodgers, J.H., Jr. and A.W. Dunn. 1991. Developing Guidelines for Constructed Wetlands to Remove Pesticides from Agricultural Runoff. Presented at the U.S. Environmental Protection Agency Symposium and Workshop on Developing Wetlands for the Use of Created and Natural Wetlands in Controlling Rural Nonpoint Source Pollution. (June 10-12) Arlington, VA. Gendusa, T.C., T.L. Beitinger and J.H. Rodgers, Jr. 1991. Toxicity of Fluoranthene from Aqueous and Sediment Sources to Pimephales promelas and Ictalurus punctatus. Presented at the 12th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (November 3-7) Seattle, WA. Robison, R.H., A.W. Dunn and J.H. Rodgers, Jr. 1991. Partitioning and Persistence of Aquatic Herbicides in Guntersville Reservoir, Alabama. Presented a the 12th Annual Meeting of the Society of Environmental Toxicology and Chemistry. November 3-7, 1991, Seattle, WA. Dunn, A.W. and J.H. Rodgers, Jr. 1991. Partitioning and Persistence of Aquatic Herbicides In Guntersville Reservoir, Alabama. Presented at the 12th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (November 3-7) Seattle, WA. Witt, W.T. and J.H. Rodgers, Jr. 1991. Effects of Sediment Associated Hexavalent and Trivalent Chromium on Daphnia magna, Hyalella azteca, Chironomus tentans, and Stylaria lacustris. Presented at the 12th Annual Meeting of the Society of Environmental Toxicoloty and Chemistry. (November 3-7) Seattle, WA. Brown, S.S., J.H. Rodgers, Jr., G.R. Gaston, A.P. McAllister, B.C. Suedel, A.W. Dunn and J.D. Mahony. 1992. Effects of Sediment-associated Copper on Stream Invertebrate Assemblages: Sediment Characteristics, Toxicity and Macrobenthos. Presented at the 13th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (November 8-12) Cincinnati, OH. Suedel, B.C. and John H. Rodgers, Jr. 1992. Development of Formulated Reference Sediments for Freshwater and Estuarine Sediment Toxicity Testing. Presented at the 13th Annual Meeting of the Society for Environmental Toxicology and Chemistry. (November 8-12) Cincinnati, OH. Dunn, A.W., J.H. Rodgers, Jr., E. Burns and A.L. Bates. 1992. Fate and Persistence of Herbicides in Guntersville Reservoir, AL. Presented at the 13th Annual Meeting of the Society for Environmental Toxicology and Chemistry. (November 8-12) Cincinnati, OH. Burres, R.E. and J.H. Rodgers, Jr. 1992. Measuring Responses of Myriophyllum spicatum to Fluoridone. Presented at the 13th Annual Meeting of the Society of Environmental Toxicology and Chemistry. November 8-12, 1992, Cincinnati, OH. Rodgers-47 Fader, P.G., K. Pigot, and J.H. Rodgers, Jr. 1992. Cytoplasmic Ion Release From Aquatic Plants as an Indicator of Membrane Injury. Presented at the 13th Annual Meeting of the Society for Environmental Toxicology and Chemistry. (November 8-12) Cincinnati, OH. Rodgers, J.H., Jr. 1992, Studies for Calibrating Fate/Effects Algorithms in HERBICIDE Version 2.0. Presented at the 27th Annual Meeting of the U.S. Army Engineers Waterways Experiment Station, Aquatic Plant Control Research Program. (November 16-19) Bellevue, WA. Giddings, J.M. and J.H. Rodgers, Jr. 1992. Large Outdoor Microcosms for Ecological Assessment of Pesticides. Presented at the Second Symposium on Environmental Toxicology and Risk Assessment: Aquatic Plant and Terrestrial, American Society for Testing and Materials. (April 26-29) Pittsburg, PA. Crossland, N.O., P.G. Fader, E.R. Kline, J.H. Rodgers, Jr., and H.G. Walker. 1992. Development of Model Streams Designed for Risk Assessments in Lotic Ecosystems. Presented at the Second Symposium on Environmental Toxicology and Risk Assessment: Aquatic Plant and Terrestrial, American Society for Testing and Materials. (April 26-29) Pittsburg, PA. Rodgers, J.H., Jr. and A.W. Dunn. 1992. Utilization of Copper Based Herbicides in Aquatic Plant Management in Guntersville Reservoir. Presented at the 11th Annual Meeting of the Mid-South Aquatic Plant Management Society. (September 30-October 2) Guntersville, AL. Dunn, A.W. and J.H. Rodgers, Jr. 1992. Partitioning and Persistence of Herbicides in the 1991 Guntersville Aquatic Plant Management Program. Presented at the 11th Annual Meeting of the Mid-South Aquatic Plant Management Society. (September 30- October 2) Guntersville, AL. Rodgers, J.H., Jr. and A.W. Dunn. 1992. Using Constructed Wetlands for Pesticide Retention and Processing. Presented at the 9th Annual Meeting of the Soil and Water Conservation Society. (August 9-12) Baltimore, MD. Crossland, N.O, P.G. Fader, E.R. Kline, J.H. Rodgers, Jr. and H.G. Walker. 1992. Model Streams Designed for Risk Assessments in Lotic Systems. Presented at the 13th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (November 8-12) Cincinnati, OH. Gillespie, B., J.H. Rodgers, Jr., N.O. Crossland and H.G. Walker. 1992. Evaluation of Parameters Used for Measuring Responses of Macroinvertebrate Assemblages in Model Streams. Presented at the 13th Annual Meeting of the Society of Environmental Rodgers-48 Toxicology and Chemistry. (November 8-12) Cincinnati, OH. Rodgers, J.H., Jr. 1992. Herbicide Residue Studies. Presented at the 1992 Review Meeting of the Joint Agency, Guntersville Project. (April 22-23) Guntersville, AL. Suedel, B.C. and John H. Rodgers, Jr. 1992. Formulated Reference Sediments for Freshwater and Estuarine Sediment Toxicity Testing. Presented at the American Society for Testing and Materials Sediment Toxicology Subcommittee Meeting (E47.03). (November 7) Cincinnati, OH. Rodgers, J.H., Jr., N.O. Crossland, P.B. Dorn, S.T. Dubey and L.K. Kravetz. 1993. The Ecological Effects of a Nonionic Surfactant in Stream Mesocosms. Platform Presented at the 14th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (November 1993) Houston, TX. Rodgers, J.H., Jr., N.O. Crossland, E.R. Kline, W.B. Gillespie, Jr., R.A. Figueroa and P. B. Dorn. 1993. Design and Use of Model Stream Mesocosms for Aquatic Safety Assessments of Surfactants. Presented at the International Workshop on Environmental Fate and Effects of Surfactants. (September 13-15) Veldhoven, The Netherlands. Gillespie, W.B., Jr., J.H. Rodgers, Jr., N.O. Crossland and P.B. Dorn. 1993. The Ecological Effects of a Nonionic Surfactant on Macroinvertebrates in Model Stream Mesocosms. Poster Discussion presented at the 14th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (November, 1993) Houston, TX. Figueroa, R.A., E.R. Kline, J.H. Rodgers, Jr. and P.B. Dorn. 1993. The Responses of Fish Exposed to a Nonionic Surfactant in Stream Mesocosms. Poster Discussion presented at the 14th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (November, 1993) Houston, TX. Deaver, E., B.C. Suedel and J.H. Rodgers, Jr. 1993. Copper Sulfate as a Reference Toxicant for Use in Sediment Toxicity Tests. Poster Discussion presented at the14th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (November, 1993) Houston, TX. Suedel, B.C., E. Deaver and J.H. Rodgers, Jr. 1993. Reducing Uncertainty in Sediment Toxicity Tests. Platform presentation at the 14th Annual Meeting of the Society of Environmental Toxicology and Chemistry. November, 1993, Houston, TX. Rodgers, J.H. Jr., E. Deaver, B.C. Suedel and P.L. Rogers. 1993. A Tiered Research Strategy for Evaluation of Silver Bioavailability in Aquatic Systems. Presented at the First International Conference on the Transport, Fate and Effects of Silver in the Environment. Madison, WI. Rodgers-49 Suedel, B.C. and J.H. Rodgers, Jr. 1993. Formulated Reference Sediments for Freshwater and Estuarine Toxicity Testing. Presented at the American Society for Testing and Materials Third Symposium on Environmental Toxicology and Risk Assessment: Aquatic, Plant and Terrestrial. (April, 1993) Atlanta, GA. Rodgers, J.H., Jr., E. Deaver and P. Rogers. 1994. Evaluation of the Bioavailability and Toxicity of Silver in Sediment. Presented at the Second International Conference on Transport, Fate and Effects of Silver in the Environment. (September 11-14) Madison, WI. Rodgers, J.H., Jr., P.L. Rogers, N. Kaul and E. Deaver. 1994. Silver Toxicity: Fact and Fiction. Presented at the Third Pollution Prevention for Silver Imaging Systems Seminar. National Association of Photographic Manufacturers. (May 11-14) Lake Buena Vista, FL. Rodgers, J.H., Jr., P.L. Rogers and E. Deaver. 1994. Responses of Aquatic Invertebrates to Silver Compounds. Platform presentation at the 15th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (October 30 - November 3) Denver, CO. Figueroa, R.A., J.H. Rodgers, Jr., R.E. Lizotte and P.B. Dorn. 1994. Responses of Fish Exposed to Nonionic Surfactants in Stream Mesocosms. Poster presented at the 15th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (October 30 - November 3) Denver, CO. Gillespie, W.B., Jr., J.H. Rodgers, Jr. and P.B. Dorn. 1994. Responses of Aquatic Invertebrates to a Nonionic Surfactant in Laboratory and Model Stream Mesocosm Exposure. Poster presented at the 15th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (October 30 - November 3) Denver, CO. Rodgers, J.H., Jr., P.B. Dorn, S.T. Dubey, W.B. Gillespie, Jr. and R.A. Figueroa. 1994. Comparative Ecological Effects of Two Homologous Nonionic Surfactants in Stream Mesocosms. Poster presented at the 15th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (October 30 - November 3) Denver, CO. Dunn, A.W. and John H. Rodgers, Jr. 1994. Uptake of Triclopyr by Eurasian Watermilfoil (Myriophyllum spicatum) Under Different Exposure Conditions. Poster presented at the 15th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (October 30 - November 3) Denver, CO. Dorn, P.B., N.R. Vergel, W.B. Hawkins, A.W. Dunn and J.H. Rodgers, Jr. 1994. Design of Pilot-scale Constructed Wetlands for Tertiary Treatment of Refinery Effluent. Poster presented at the 15th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (October 30 - November 3) Denver, CO. Rodgers-50 Deaver, E. and J.H. Rodgers, Jr. 1994. Evaluations of Bioavailable Copper in Amended Wetland Sediments. Poster presented at the 15th Annual Meeting of the Society of Environmental Toxicology and Chemistry. (October 30 - November 3) Denver, CO. Deaver, E. and J.H. Rodgers, Jr. 1994. Analysis of Copper in Aqueous Systems. Presented at the Annual Meeting of the Aquatic Plant Management Society. (July 10- 13) San Antonio, TX. Deaver, E. and J.H. Rodgers, Jr. 1994. Analysis of Copper in Aqueous Systems. Presented at the Annual Meeting of the South Carolina Aquatic Plant Management Society. (August, 1994) Columbia, SC. Deaver, E. and J.H. Rodgers, Jr. 1994. Analysis of Bioavailable Copper in Amended Wetland Sediments. Presented at the Annual Meeting of the Agronomy Society of America. (November 12-17) Seattle, WA. Deaver, E. and J.H. Rodgers, Jr. 1994. Analysis of Copper in Aqueous Systems. Presented at the Annual Meeting of the Mid-South Aquatic Plant Management Society. (October, 1994) Birmingham, AL. Rodgers, J.H., Jr. 1994. Current Research Activities at the University of Mississippi's Biological Field Station and Center for Water and Wetland Resources. Presented to the Annual Meeting of the Mid-South Aquatic Plant Management Society. (October, 1994) Birmingham, AL. Rodgers, J.H., Jr., W.B. Hawkins, A.W. Dunn and T.L. Deardorff. 1994. An Evaluation of Potential Imparts of Bleached Kraft Mill Effluents on the Lower Sulphur River, Texas- Arkansas. Presented at the Second International Conference on Environmental Fate and Effects of Bleached Pulp Mill Effluents. (November 6-9) Vancouver, B.C. Rodgers, J.H., Jr. 1995. Use of Copper for Aquatic Plant Management. Presented at the 14th Annual Meeting of the Mid-South Aquatic Plant Management Society. (October 11- 13) Sheffield, AL. Deaver, E. and J.H. Rodgers, Jr. 1995. Measuring Bioavailable Copper Using Anodic Stripping Voltammetry. Presented at the 14th Annual Meeting of the Mid-South Aquatic Plant Management Society. (October 11-13) Sheffield, AL. Rodgers, J.H., Jr. and A.W. Dunn. 1995. Constructed Wetlands Integratively Designed for Transfer and Transformation of Copper, Lead and Zinc. Presented at the 14th Annual Meeting of the Mid-South Aquatic Plant Management Society. (October 11-13) Sheffield, AL. Rodgers-51 Hawkins, W.B. and J.H. Rodgers, Jr. 1995. Utilization of Scirpus californicus [(C.A. Meyer) Steud.] in Constructed Wetlands. Presented at the 14th Annual Meeting of the Mid-South Aquatic Plant Management Society. (October 11-13) Sheffield, AL. Lizotte, R.E., J.H. Rodgers, Jr., P.B. Dorn, S.T. Dubey, W.B. Gillespie, Jr. and R.A. Figueroa. 1995. Comparative Ecological Effects of Two Homologous Nonionic Surfactants in Stream Mesocosms. Sigma Xi, The University of Mississippi Chapter and Office of Research/Graduate/Undergraduate Student PosterSymposium. Deaver, E. and J.H. Rodgers, Jr. 1995. Investigations of Copper Speciation and Bioavailability. Presented at the 16th Annual Meeting and Second World Congress of the Society of Environmental Toxicology and Chemistry. (November 5-9) Vancouver, B.C. Hawkins, W.B., A.W. Dunn, J.H. Rodgers, Jr. and P.B. Dorn. 1995. Pilot-scale Constructed Wetlands for Tertiary Treatment of Refinery Effluent. Presented at the 16th Annual Meeting and Second World Congress of the Society of Environmental Toxicology and Chemistry. (November 5-9) Vancouver, B.C. Gillespie, W.B., Jr., J.H. Rodgers, Jr., P.B. Dorn and S.T. Dubey. 1995. Responses of Aquatic Invertebrates to Three Homologous Nonionic Surfactants in Model Stream Mesocosm Exposures. Presented at the 16th Annual Meeting and Second World Congress of the Society of Environmental Toxicology and Chemistry. (November 5-9) Vancouver, B.C. Dunn, A.W. and J.H. Rodgers, Jr. 1995. Responses of a Submerged Aquatic Plant and Periphyton to a Nonionic Surfactant in Model Stream Mesocosm Exposures. Presented at the 16th Annual Meeting and Second World Congress of the Society of Environmental Toxicology and Chemistry. (November 5-9) Vancouver, B.C. Rodgers, J.H., Jr., P.B. Dorn, W.B. Gillespie,Jr. and S.T. Dubey. 1995. Effects of Three Homologous Nonionic Surfactants in Model Stream Mesocosm Exposures. Presented at the 16th Annual Meeting and Second World Congress of the Society of Environmental Toxicology and Chemistry. (November 5-9) Vancouver, B.C. Lizotte, R.E., Jr., J.H. Rodgers, Jr., P.B. Dorn and S.T. Dubey. 1995. Effects of Three Homologous Nonionic Surfactants on Fish in Stream Mesocosms. Presented at the 16th Annual Meeting and Second World Congress of the Society of Environmental Toxicology and Chemistry. (November 5-9)Vancouver, B.C. Rodgers, J.H., Jr., E. Deaver and P.L. Rogers.1995. Partitioning and Effects of Silver in Amended Freshwater Sediments. Presented at the Third International Conference on Transport, Fate and Effects of Silver in the Environment. (August 6-9) Washington, D.C. Rodgers-52 Deardorff, T.L., J.H. Rodgers, Jr., D.P. Felder, and S.J. D'Surney. 1998. A multifaceted investigation of the aquatic ecosystems near a bleached and unbleached kraft mill. Presented at the Third International Symposium on Aquatic Impacts of Pulp and Paper Mills, Nov. 1998. New Zealand. Mastin, B.J. and Rodgers, J.H., Jr. 1998. Toxicity and bioavailability of copper herbicides (Clearigate®, Cutrine®-Plus, and copper sulfate) to freshwater animals. 19tH Annual meeting, Society of Environmental Toxicology and Chemistry, Nov., Charlotte, NC. p.212. Moore, M.T., W.B. Gillespie, Jr., and J.H. Rodgers, Jr. 1998. Constructed wetlands to mitigate agricultural pesticide runoff. 19th Annual Meeting, Society of Environmental Toxicology and Chemistry, Nov., Charlotte, NC. p.284. Mastin, B.J. and Rodgers, J.H., Jr. 1998. Characterization and assessment of Lyngbya- dominated cyanobacteria "blooms" in the SB-1 Reservoir Springhill, Louisiana. Biology Department University of Mississippi. Maciorowski, A.F., Reinert, K., and Rodgers, J.H., Jr. 1998. Ethics in Ecological Risk Assessment: An Overview. publ. abstr. 19th annual meeting Society of Environmental Toxicology and Chemistry, Nov. Charlotte, NC. Bohannon, A.L., Moore, M.T., Cooper, M., and Rodgers, J.H. Jr. 1998. Effects of Chlorpyrifos on Macroinvertebrates in Constructed Wetlands. Publ. abstr. 19th annual meeting Society of Environmental Toxicology and Chemistry. Nov. Charlotte, NC. Dorn, P.B.,Tattersfield, L.J., Raney, K.H., and Rodgers, J.H. Jr. 1998. Development of Effects Data for Alcohol Ethoxylate Surfactants using Stream Mesocosms. Publ. abstr. 19th annual meeting Society of Environmental Toxicology and Chemistry. Nov. Charlotte, NC. p. 175. Huggett, D.B., Muller, S.L., Bohannon, A.L., and Rodgers, J.H.Jr., Adams, D.L., Deardorff, T.L. 1998. Toxicity Assessment of Historically Contaminated Sediments. Publ. abstr. 19th annual meeting Society of Environmental Toxicology and Chemistry. Nov. Charlotte, NC. p.209. Mastin, B.J., and Rodgers, J.H., Jr. 1998. Toxicity and Bioavailability of Chelated- Copper Herbicides Clearigate®, Cutrine®-Plus and Copper Sulfate. Publ. abstr. 19th annual meeting Society of Environmental Toxicology and Chemistry. Nov. Charlotte, NC. p.212. Rodgers, J.H., Jr., Fisher, R.P., and Festa, J.L. 1998. Development of a North American research strategy to assess potential reproductive effects of pulp mill effluents on fish- focus on hormone-mediated effects and assessment. Publ. abstr. 19th annual meeting Rodgers-53 Society of Environmental Toxicology and Chemistry. Nov. Charlotte, NC. p. 233 Gillespie, W.B. Jr., Rodgers, J.H., Jr., Cooper, C.M., and Smith S. 1998. Constructed Wetlands to Mitigate Agricultural Pesticide Runoff. Pub[. abstr. 19th annual meeting Society of Environmental Toxicology and Chemistry. Nov. Charlotte, NC. p. 284. Huddleston, G.M. III, Gillespie, W.B., Jr., Rodgers, J.H., Jr. 1998. Abatement of Ammonia and Biochemical Oxygen Demand in a Petroleum Refinery Effluent Using Constructed Wetlands. Publ. abstr. 19th annual meeting Society of Environmental Toxicology and Chemistry. Nov. Charlotte, NC. p. 284. Muller, S.L., Huggett, D.B., Rodgers, J.H., Jr. 1998. Effects of Copper Sulfate on Typha latifolia Seed Germination and Early Seedling Growth in Aqueous and Sediment Exposures. Publ. abstr. 19th annual meeting Society of Environmental Toxicology and Chemistry. Nov. Charlotte, NC. p. 287. Moore, M.T., S. Smith, Jr., and C.M. Cooper. 1999. Comparative mitigation of chlorpyrifos, atrazine, and meta chlor-associated runoff using constructed wetlands. Presented at the 20th Annual Meeting of the Society of Environmental Toxicology and Chemistry. Philadelphia, PA, 14-18 November 1999. p.102. Bohannon, A.L., M.T. Moore, and J.H. Rodgers, Jr. 1999. Evaluation of bench-scale constructed wetland microcosms for potential tertiary treatment of produced water from a petroleum refinery. Presented at the 20th Annual Meeting of the Society of Environmental Toxicology and Chemistry. Philadelphia, PA, 14-18 November 1999. p..271. Huddleston, G.M., A.L. Schwartzman, and J.H. Rodgers, Jr. 1999. Risk mitigation of a complex effluent using constructed wetlands. Presented at the 20th Annual Meeting of the Society of Environmental Toxicology and Chemistry. Philadelphia, PA, 14-18 November 1999. p..272. Mastin, B.J., J.H. Rodgers, Jr. and T.L. Deardorff. 1999. Risk assessment of cyanobacteria-dominated algal "blooms" in a north Louisiana reservoir. Presented at the 20th Annual Meeting of the Society of Environmental Toxicology and Chemistry. Philadelphia, PA, 14-18 November 1999. p.284. Huddleston, G.M., J.H. Rodgers, Jr., D.B. Huggett, M.T. Moore, and C.M. Cooper. 1999. Herbicide effects on Typha latifolia (Linnaeus) germination and root and shoot development. Presented at the 20th Annual Meeting of the Society of Environmental Toxicology and Chemistry. Philadelphia, PA, 14-18 November 1999. p. 158. Schwartzman, A.L., B.J. Mastin, and J.H. Rodgers, Jr. 1999. The role of plants for influencing redox potential in the root zone in different hydrosoils. Presented at the 20th Rodgers-54 Annual Meeting of the Society of Environmental Toxicology and Chemistry. Philadelphia, PA, 14-18 November 1999. p. 158. Winfield, L.E., J.H. Rodgers, Jr., S.J. D'Surney and C.R. Lee. 1999. Phytotoxicity of RDX Exposure (<12 days) to selected terrestrial plants. Presented at the 20th Annual Meeting of the Society of Environmental Toxicology and Chemistry. Philadelphia, PA, 14-18 November 1999. p.. 158. Huddleston, G.M., J.H. Rodgers, Jr., B.J. Mastin, S.E. Woods and D. McHenry. 1999. Macroinvertebrate survey of the Tenn-Tom Waterway in the vicinity of a pulp and paper effluent discharge: Factors influencing rapid bioassessment interpretation. Presented at the 20th Annual Meeting of the Society of Environmental Toxicology and Chemistry. Philadelphia, PA, 14-18 November 1999. p. 245. Rodgers, Jr., J.H. 1999. Risk assessment of herbicides for aquatic use. Presented at the 18th Annual Meeting of the Midsouth Aquatic Plant Management Society. Gulf Shores, AL, 20-22 October 1999. Rodgers, Jr., J.H. 1999. Risk assessment of herbicides for aquatic use. (Keynote Address) Presented at the Annual Meeting of the South Carolina Aquatic Plant Management Society. Columbia, SC, 12-13 August 1999. Rodgers, Jr., J.H. 1999. Environmental toxicology and ecotoxicology. Presented at a workshop on Partners in Scientific Collaboration. Oak Ridge National Laboratory, Oak Ridge, TN, 18-19 August 1999. Sponsored by AAAS, NSF, U.S. DOE and ORNL. Huddleston, G.M., III, Mastin, B.J., Rodgers, J.H., Jr., Woock, S.E., McHenry, D. 1999. Macroinverteb rate survey of the Tennessee-Tombigbee Waterway in the vicinity of a pulp and paper effluent discharge: factors influencing rapid bioassessment interpretation. Annual Meeting, Society of Environmental Toxicology and Chemistry., Philadelphia, PA. Rodgers, J.H., Jr. 1999. Toxic effects of forest herbicides on aquatic organisms. Presented at the Symposium Pesticides and the Forest Environment. April 13-15, 1999 Nacogdoches, Texas. Rodgers, J.H., Jr. 1999. SETAC-US EPA. WET Initiatives: All WET and Nothing but WET. Presented at Air and Waste Management Association Environmental Permitting Symposium (February 17-19, 1999), Research Triangle Park, NC. Winfield, L.E., Lee, C.R., Rodgers, J.H., Jr., and D'Surney, S.J. 1999. Effects of short- term exposure to RDX amended mollisols in wild/cover plants. Poster presentation. Annual Meeting Soc. of Toxicology. March 1999. New Orleans, LA. Rodgers-55 Winfield, L.E., D'Surney, S.J., Rodgers, J.H., Jr., and Lee, C.R. 1999. Phytotoxicity of RDX exposure (<12 days) to selected terrestrial plants. Poster presentation. 20th Annual Meeting of Society of Environmental Toxicology and Chemistry. Nov 1999. Philadelphia, PA. Huddleston, G.M., Rodgers, J.H., Jr.,Huggett, D.B., Moore, M.T., and Cooper, C.M. 1999. Herbicide Effects on Typha latifolia (Linneaus) Germination and Root ant Shoot Development. Publ. abstr. 20t annual meeting Society of Environmental Toxicology and Chemistry. Nov. Philadelphia, PA. Winfield, L.E., Rodgers, J.H. Jr., D'Surney, S.J., and Lee, C.R. 1999. Phytotoxicity of RDX Exposure (<12 days) to Selected Terrestrial Plants. Publ. abstr. 20t annual meeting Society of Environmental Toxicology and Chemistry. Nov. Philadelphia, PA. Ausley, L.W., D.T. Burton, D.L. Denton, P.B. Dorn, W.L. Goodfellow, Jr., J.R. Gully, T.J. Norberg-King, J.H. Rodgers Jr., and W.T. Waller. 2000. Watershed Management: Historical Perspective for the Future. Society of Environmental Toxicology and Chemistry, Nashville, TN. November 12-16, 2000 (Platform). p. 29. Huddleston, III, G.M., A.L. Schwartzman, and J.H. Rodgers, Jr. 2000. Constructed Wetland Design for Decreasing Copper Bioavailability Associated with an Aqueous Matrix. Society of Environmental Toxicology and Chemistry, Nashville, TN. November 12-16, 2000 (Poster). p. 283. Mastin, B.J. and J.H. Rodgers, Jr. 2000. Design and Performance of Constructed Wetlands for Treatment of Petroleum in an Aqueous Matrix. Society of Environmental Toxicology and Chemistry, Nashville, TN. November 12-16, 2000 (Poster). p. 284. Murray-Gulde, C.L., J.E. Heatley, J.H. Rodgers, Jr., J.E. Myers, and J.F. Hall. 2000. Design of a Pilot-Scale Constructed Wetland Treatment System for Oilfield Produced Waters. Carolina Regional of Society of Environmental Toxicology and Chemistry, Wilmington, NC. March 31-April 1, 2000 (Poster). p. 284. Rodgers, Jr., J.H., M.T. Moore, C.M. Copper, and S. Smith, Jr. 2000. Constructed Wetlands for Mitigation of Risks from Golf Course Runoff. Society of Environmental Toxicology and Chemistry, Nashville, TN. November 12-16, 2000 (Poster). p. 191. Schwartzman, A.L., G.M. Huddleston, III, and J.H. Rodgers, Jr. 2000. The Role of Scirpus californicus (Giant Bulrush) in Constructed Wetlands for Remediation of Copper-Contaminated Wastewater. Society of Environmental Toxicology and Chemistry, Nashville, TN. November 12-16, 2000 (Poster). p.283. Sherrard, R.M. and J.H. Rodgers, Jr. 2000. Design of Constructed Wetland Anaerobic Reactors for Treatment of Trichloroethylene and Perch loroethylene. Society of Rodgers-56 Environmental Toxicology and Chemistry, Nashville, TN. November 12-16, 2000 (Poster). p. 284. Sherrard, R.M. and J.H. Rodgers, Jr. 2000. Design of Constructed Wetland Anaerobic Reactors for Treatment of Trichloroethylene. Carolina Regional Meeting of Society of Environmental Toxicology and Chemistry, Wilmington, NC. March 31-April 1, 2000 (Poster). Winfield, L., S. D'Surney, C. Lee, and J.H. Rodgers, Jr. 2000. A Comparison of the Responses of Agronomic and Wild/Cover Plants to RDX Amended Grenada and Bowdry Soils. Society of Environmental Toxicology and Chemistry, Nashville, TN. November 12-16, 2000 (Poster). p. 236. Winfield, L., J.H. Rodgers, Jr., C.Lee, S. D'Surney, and D. Brandon. 2000. The Phytotoxicity and Bioaccumulation of RDX by Sunflower (Helianthus annuus L.) Plants. Society of Environmental Toxicology and Chemistry, Nashville, TN. November 12-16, 2000 (Poster). p. 236. Rodgers JH Jr., and Myers JE. 2001. Treatment wetlands as sustainable technology for water treatment: fundamentals. Presented at the 5th International Congress on Health, Safety, and Environment (COSSMAP): Panama City, Panama; July 11-14, 2001. Rodgers JH Jr. 2001. Treatment wetlands as sustainable technology for water treatment: domestic wastewater. Presented at the 5th International Congress on Health, Safety, and Environment (COSSMAP): Panama City, Panama; July 11-14, 2001. Rodgers JH Jr. 2001. Treatment wetlands as sustainable technology for water treatment: stormwater. Presented at the 5th International Congress on Health, Safety, and Environment (COSSMAP): Panama City, Panama; July 11-14,2001. Rodgers, JH Jr. 2001. Environmental research at Clemson University and opportunities for collaboration. Presented at Universidad Catolica Santa Maria La Antigua, El Dorado, Panama; July 13, 2001. Mastin, B.J., J.H. Rodgers, Jr. and Y.T. Shah. 2001. Hybrid cavitation/ constructed wetland reactors for treatment of chlorinated and non-chlorinated organics. Chemical Engineering Tech 24(8): 97A-105A. Winfield, L.E., D'Surney, S.J. and Rodgers, J.H., Jr. 2001. The response of terrestrial plants to hexahydro-1,3,5-trinitro-1,3,5-triazine (RDX) exposures: Part 1- Short-term (<12 days) exposures using cover plants. Submitted to J. of Ecotoxicology. Winfield, L.E., Rodgers, J.H., Jr., and D'Surney, S.J. 2001. The response of terrestrial Rodgers-57 plants to hexahydro-1,3,5-trinitro-1,3,5-triazine (RDX) exposures: Part II- Short-term (<12 days) exposure using five crop plants. Submitted to J. of Ecotoxicology. Windfield, L.E., D'Surney, S.J. and Rodgers, J.H., Jr. 2001. The response of sunflower (Helianthus annuus L.) plants long-term (2,4,and 6 weeks) Hexahydro-1,3,5-trinitro- 1,3,5-triazine (RDX) exposures: Part III-Growth responses of two life stages. Submitted to J. of Ecotoxicology. Windfield, L.E., Rodgers, J.H.,Jr., and D'Surney, S.J. 2001. The response of two life stages of sunflower (Helianthus annuus L) plant to long-term (2,4,and 6 weeks) RDX exposure: Part IV-Bioconcentration and phytotoxic responses. Submitted to J. of Ecotoxicology. Winfield, L.E., D'Surney, S.J., and Rodgers, J.H., Jr. 2001. The response of terrestrial plants to short-term hexahydro-1,3,5-trinitro-1,3,5-triazine (RDX) exposure. Accepted for publication in Proceedings, Conference on Sustainability of Wetlands and Water Resources. Center for Water and Wetland Resources at the Univ. of MS Biology Field Station. University, MS. Winfield, L., S. D'Surney and J.H. Rodgers, Jr. 2001. Development of a short-term screening method to assess RDX Bioavailability and phytotoxicity. Presented at the 22nd Annual Meeting of the Society of Environmental Toxicology and Chemistry. 11-15 November 2001, Baltimore. Rodgers, J.H., Jr., L.W. Ausley, D. Burton, D.L. Denton, P.B. Dorn, W. L. Goodfellow, J. Gully, T.J. Norberg-King, and W.T. Waller. 2001 TMDL's: After point sources, what can we do next? Presented at the 22nd Annual Meeting of the Society of Environmental Toxicology and Chemistry. 11-15 November 2001, Baltimore. P. 59. Johnson, A.R., and J.H. Rodgers, Jr. 2001. Scaling in Ecotoxicity: theory, evidence and research needs. Presented at the 22nd Annual Meeting of the Society of Environmental Toxicology and Chemistry. 11-15 November 2001, Baltimore. P. 84. Mastin, B.J., G.M. Huddleston and J.H. Rodgers, Jr. 2001. Partitioning of copper to Scirpus californicus organic matter: effects on toxicity to Ceriodaphnia dubia. Presented at the 22nd Annual Meeting of the Society of Environmental Toxicology and Chemistry. 11-15 November 2001, Baltimore. P. 157. Murray-Gulde,C.L., J.E. Heatley, A.L. Schwartzman and J.H. Rodgers, Jr. 2001. Toxicity of Clearigate, Cutrine-Plus and Copper Sulfate to Raphidocelis subcapitata, Ceriodaphnia dubia and Pimephales promelas. Presented at the 22nd Annual Meeting of the Society of Environmental Toxicology and Chemistry. 11-15 November 2001, Baltimore. p. 206. Rodgers-58 Sherrard, R.M. C.L. Murray-Guide, and J.H. Rodgers, Jr. 2001. Comparative toxicity of chlorothalonil and chlorpyrifos: Ceriodaphnia dubia and Pimephales promelas. Presented at the 22nd Annual Meeting of the Society of Environmental Toxicology and Chemistry. 11-15 November 2001, Baltimore. P.338. Mastin, B.J., Rodgers, J.H., Jr. 2001. Design and performance of constructed wetlands for treatment of stormwater. Constructed Wetlands for Water Quality Improvement, Clemson University, Departments of Plant Pathology and Physiology, and Department of Industrial Engineering. Mastin, B.J. Rodgers, J.H.,Jr., Deardorff, T.L. 2001. Risk evaluation of cyanobacterial- dominated algal blooms in a North Louisiana reservoir. Annual meeting Society of Environmental Toxicology and Chemistry, Carolinas Chapter. Mastin, B.J., Huddleston, G.M. III, Rodgers, J.H., Jr. 2001. Partitioning of copper to Scirpus californicus organic matter: Effects on toxicity to Ceriodaphnia dubia. Presented at the 22nd Annual Meeting of the Society of Environmental Toxicology and Chemistry. 11-15 November 2001, Baltimore. Rodgers, J.H. Jr. 2001. Strategies for Risk Characterizations of Contaminated Sediments. Invited speaker. Conference De Prestige Cirtox. Centre interuniversitaire de recherche en toxicologie (CIRTOX). Universite de Montreal. May 31, 2001. (invited plenary lecture) Winfield, L.E., D.Surney, S.J. and Rodgers, J.H., Jr. 2001. Development of a short-term method to assess RDX bioavailability and phytotoxicity. Accepted for presentation during 22nd Annual Meeting of Society of Environmental Toxicology and Chemistry. Nov. 2001. Baltimore, MD. Winfield, L.E., D'Surney, S.J., and Rodgers, J.H., Jr. 2001. The growth response of selected terrestrial plants to RDX exposure. Invited speaker for special symposium. Annual Meeting of the American Phytopathology Society. Aug. 2001. Salt Lake City, UT. Murray-Gulde, C., Heatley, J.E., Karanfil, T., Rodgers, Jr., J.H. and Myers, J.E. (in press). Performance of a Hybrid Reverse Osmosis-Constructed Wetland Treatment System for Brackish Produced Water. Water Research Rodgers, J.H., Jr. 2002. Case Study: A TMDL for copper. Presented at the 23rd Annual Meeting of the Society of Environmental Toxicology and Chemistry. Nov., 2002, Salt Lake City, UT. Rodgers, J.H., Jr., J.E. Heatley, and C.L. Murray-Gulde. 2002. Toxicity of five copper- containing algaecides to selected algae and animal species. Presented at the 23` Rodgers-59 Annual Meeting of the Society of Environmental Toxicology and Chemistry. Nov., 2002, Salt Lake City, UT. Murray-Guide, C.L., J. Bearr, J. Gallagher, J. Heatley, G.M. Huddleston III, and J.H. Rodgers, Jr. 2002. Design and evaluation of a constructed wetland treatment sysem for decreasing the concentration and bioavailability of copper in a wastestream. Presented at the 23rd Annual Meeting of the Society of Environmental Toxicology and Chemistry. Nov., 2002, Salt Lake City, UT. Mastin, B.J.and J.H. Rodgers, Jr. 2002. Discerning toxic fractions of crankcase oil and diagnostic responses of freshwater testing organisms. Presented at the 23rd Annual Meeting of the Society of Environmental Toxicology and Chemistry. Nov., 2002, Salt Lake City, UT. Murray-Gulde, C.L., G.M. Huddleston III, and J. H. Rodgers, Jr. 2002. Comparison of a microcosm-scale and full-scale constructed wetland treatment system designed to treat a copper-contaminated wastewater. Presented at the 23rd Annual Meeting of the Society of Environmental Toxicology and Chemistry. Nov., 2002, Salt Lake City, UT. Murray-Gulde, C.L. and J.H. Rodgers, Jr. 2002. Contributions of Scirpus californicus in a constructed wetland system receiving copper contaminated wastewater. Presented at the 23rd Annual Meeting of the Society of Environmental Toxicology and Chemistry. Nov., 2002, Salt Lake City, UT. Gallagher, J.S., G.M. Huddleston III, and J.H. Rodgers, Jr. 2002. Toxicity of lake sediments to Hyalella azteca Sausure and Ceriodaphnia dubia Richard following copper-herbicide applications. Presented at the 23rd Annual Meeting of the Society of Environmental Toxicology and Chemistry. Nov., 2002, Salt Lake City, UT. Johnson, A.R. and J.H. Rodgers, Jr. 2003. Scaling in ecotoxicology: theory, evidence and research needs. Presented at the 7th International Conference on Aquatic Ecosystem Health and Management Society, Sep., 2003. Lyon, France. Huddleston, G.M., J.C. Arrington, and J.H. Rodgers, Jr. 2003. Winter removal of BOD and solids from an industrial effluent using constructed wetlands. Presented at the 24th Annual Meeting of the Society of Environmental Toxicology and Chemistry. Nov., 2003, Austin, TX. Garber, K.V., J.S. Gallagher, J.H. Rodgers, Jr., and A.R. Johnson. 2003. Measuring and modeling changes over time of fecal coliform densities in aquatic systems. Presented at the 24th Annual Meeting of the Society of Environmental Toxicology and Chemistry. Nov., 2003, Austin, TX. Stag, C.L. and J.H. Rodgers, Jr. 2003. Identification of toxic fractions of a formulated Rodgers-60 produced water and diagnostic responses of Ceriodaphnia dubia. Presented at the 24th Annual Meeting of the Society of Environmental Toxicology and Chemistry. Nov., 2003, Austin, TX. Duke, B.M., and J.H. Rodgers, Jr. 2003. Comparative toxicity of a copper containing algaecide to four algal species. Presented at the 24th Annual Meeting of the Society of Environmental Toxicology and Chemistry. Nov., 2003, Austin, TX. Gallagher, J.S., K.V. Garber and J. H. Rodgers, Jr. 2003. Mitigating risks of domestic wastewater using model constructed wetlands: Influence of HRT and loading. Presented at the 24th Annual Meeting of the Society of Environmental Toxicology and Chemistry. Nov., 2003, Austin, TX. Rodgers, J.H., Jr. 2003. After the TMDL, what do we do? Presented at the TMDL Short Course at the 24th Annual Meeting of the Society of Environmental Toxicology and Chemistry. Nov., 2003, Austin, TX. Rodgers, J.H., Jr., C.L. Murray-Guide and G.M. Huddleston, III. 2003. Expanding functional roles of vascular aquatic plants: Schoenoplectus californicus as an example. Presented at the 43rd Annual Meeting of the Aquatic Plant Management Society, July, 2003. Portland, Maine. Rodgers, J.H., Jr. 2003. Role of Schoenoplectus californicus in constructed wetlands for treatment of metals at Savannah River Site. Presented at the Annual Review Meeting of the USDA/ARS Jimmy carter Plant Materials Center. June, 2003. Americus, GA. Rodgers, J.H., Jr. 2003. Using copper containing algacides and herbicides in aquatic systems. Presented at the Annual Meeting of the Mid-West Aquatic Plant Management Society. March, 2003. Columbus, OH. Rodgers, J.H., Jr. and J. Thomas. 2003. Evaluation of the fate and effects of pulp and paper mill effluents from a watershed multistressor perspective: Progress to date and future opportunities. Presented at the 5th International Conference on the Fate and Effects of Pulp and Paper Mill Effluents and the 7th International Water Association Symposium on Forest industry Wastewaters. June, 2003. Seattle, WA. Rodgers, J.H., Jr. 2003. Expanding functional roles for Schoenoplectus californicus in constructed wetlands for treating metals. Presented (invited) at the Annual Meeting of the South Carolina Aquatic Plant Management Society. August, 2003. Monks Corner, Sc. Rodgers, J.H., Jr. 2003. Schoenoplectus californicus: Expanding role in constructed wetlands for treating metals. Presented at the Annual Meeting of the MidSouth Aquatic Plant Management Society. Oct. 2003. Auburn University, AL. Rodgers-61 Johnson, B.M., L.E. Ober, J.W. Castle, and J.H. Rodgers, Jr. 2005. Treating Natural Gas Storage Produced Waters Using Constructed Wetland Treatment Systems. Presented at the International Symposium on Phytotechnology (U.S. EPA), March, 2005. Atlanta, GA. Eggert, D., J.H. Rodgers, Jr., G.M. Huddleston III, C. Guide, and F.D. Mooney. 2005. Design Constructed Wetland Treatment Systems for Flue Gas Desulfurzation Wastewaters. Presented at the International Symposium on Phytotechnology (U.S. EPA), March, 2005. Atlanta, GA. Rodgers, J.H., Jr., R. Jones, M. Duke, S. Lankford and W. Anderson. 2005. Lyngbya Growth and Control: We Are Working On It? Presented at the Annual Meeting of the Aquatic Plant Management Society. July, 2005. San Antonio, TX. Duke, B.M., O.R. Tedrow and J.H. Rodgers, Jr. 2005. Site-specific Management of Problematic Algae Using a Copper-containing Algaecide. Presented at the Annual Meeting of the Aquatic Plant Management Society. July, 2005. San Antonio, TX. Rodgers, J.H., Jr., R. Jones, M. Duke, S. Lankford and W. Anderson. 2005. Lyngbya Growth and Control: We Are Working On It? Presented at the 27th Annual Meeting of the South Carolina Aquatic Plant Management Society. August, 2005. Myrtle Beach, SC. Duke, B.M., O.R. Tedrow and J.H. Rodgers, Jr. 2005. Site-specific Management of Problemattic Algae Using a Copper-containing Algaecide. Presented at the 27th Annual Meeting of the South Carolina Aquatic Plant Management Society. August, 2005. Myrtle Beach, SC. Johnson, B.M., L.E. Ober, J.W. Castle, and J.H. Rodgers, Jr. 2005. Treating Natural Gas Storage Produced Waters Using Constructed Wetland Treatment Systems. Presented at the Annual Meeting of the American Association of Petroleum Geologists, September, 2005. Morgantown, WV. Rodgers, J.H., J.W. Castle, B.M. Johnson, and L.E. Ober. 2005. Progress of Design of Hybrid Constructed Wetland Treatment Systems for Natural Gas Storage Produced Waters. Presented at the Annual Meeting of the Gas Storage Technology Consortium (U.S. DOE), August, 2005, Pittsburg, PA. Castle, J.W., J.H. Rodgers, Jr., B.M. Johnson, and L.E. Ober. 2005. A Demonstration- Scale Hybrid Construction Wetland Treatment System for Gas Storage Produced Waters. Presented at the Annual Meeting of the Gas Storage Technology Consortium (U.S. DOE), August, 2005, Pittsburg, PA. Rodgers-62 Deardorff, T.L. and J.H. Rodgers, Jr. 2006. The efficacy of a constructed wetland for the pulp and paper industry: From the laboratory to a full-scale trial. Presented at the 27th Annual Meeting of the Society of Environmental Toxicology and Chemistry, Nov. 5-7, 2006, Montreal, CANADA. (ABSTRACTS p. 218). Damiri, B.R. and J.H. Rodgers, Jr. 2006. Responses of Typha latifolia to aqueous boron exposures. Presented at the 27th Annual Meeting of the Society of Environmental Toxicology and Chemistry, Nov. 5-7, 2006, Montreal, CANADA. (ABSTRACTS p.243). Eggert, D.A., W.C. Bridges and J.H. Rodgers, Jr. 2006. Ceriodaphnia dubia exposed to mercuric nitrate: Assessment of sample size and statistical analysis for a 7d static/renewal toxicity test. Presented at the 27th Annual Meeting of the Society of Environmental Toxicology and Chemistry, Nov. 5-7, 2006, Montreal, CANADA. (ABSTRACTS p. 246). Duke, B.M., O.R. Tedrow and J.H. Rodgers, Jr. 2006. Development of a planktonic algal bioassay using site water and copper containing algaecides. Presented at the 27th Annual Meeting of the Society of Environmental Toxicology and Chemistry, Nov. 5-7, 2006, Montreal, CANADA. (ABSTRACTS p. 245). Kushner, L.R., J.H. Rodgers, Jr. and D.A. Eggert. 2006. Potential toxicity of aqueous exposures of cadmium, chromium, lead and zinc to Ceriodaphnia dubia. Presented at the 27th Annual Meeting of the Society of Environmental Toxicology and Chemistry, Nov. 5-7, 2006, Montreal, CANADA. (ABSTRACTS p. 301). Johnson, B.M., D.A. Eggert and J.H. Rodgers, Jr. 2006. Treatment of Arsenic, Mercury, Nitrogen and Selenium in Flue Gas Desulfurization Water Using Pilot-Scale Constructed Wetland treatment Systems. Presented at the 27th Annual Meeting of the Society of Environmental Toxicology and Chemistry, Nov. 5-7, 2006, Montreal, CANADA. (ABSTRACTS p. 301). Rodgers, J.H., Jr. 2007. Do algae spill their guts after treatment with algaecides?: A test of the "leaky cell" hypothesis. Presented at the 8th Annual Meeting of the Northeast Aquatic Plant Management Society, Jan.16-17, 2007. West Dover, Vermont. Johnson, B.M. and J.H. Rodgers, Jr. 2007. Responses of sentinel non-target species to copper-containing algaecides. Presented at the 8th Annual Meeting of the Northeast Aquatic Plant Management Society, Jan.16-17, 2007. West Dover, Vermont. Rodgers, J.H., Jr. 2007. Do algae spill their guts after treatment with algaecides?: A test of the "leaky cell" hypothesis. Presented at the 28th Annual Meeting of the South Carolina Aquatic Plant Management Society, Aug. 16-18, 2006. Springmaid Beach, SC. Rodgers, J.H., Jr. 2006. Adaptive Water Resource Management and Harmful Algal Rodgers-63 Blooms. Presented at the Annual Meeting of the Texas Aquatic Plant Management Society. Sep. 11-13, 2006. Jasper, TX. Rodgers, J.H., Jr. 2006. Selecting and managing plants for constructed wetland treatment systems. Presented at the 30th Annual Meeting of the Florida Aquatic Plant Management Society, Oct.30- Nov.2, 2006. St. Petersburg, FL. Rodgers, J.H., Jr. and J.W. Castle 2006. Demonstration-scale constructed wetland system for treatment of produced waters from underground gas storage. Presented at the Gas Storage Technology Consortium Technology Transfer Workshop, Oct. 4, 2006. San Francisco, CA. Rodgers, J.H., Jr. 2007. Do algae spill their guts after treatment with an algaecide?; A test of the "leaky cell" hypothesis. Presented at the 27th Annual Meeting of the MidWest Aquatic Plant Management Society, March 3-5, 2007. Milwaukee, WI. Johnson, B.M. and J.H. Rodgers, Jr. 2007. Responses of sentinel non-target species to copper-containing algaecides. Presented at the 27th Annual Meeting of the MidWest Aquatic Plant Management Society, March 3-5, 2007. Milwaukee, WI. Rodgers, J.H., Jr. 2007. Toxicology of herbicides. Presented at the 26th Annual Meeting of the Western Aquatic Plant Management Society, March 25-27, 2007. Coeur d'Alene, ID. Rodgers, J.H., Jr. 2006. Do algae spill their guts after treatment with an algaecide?; A test of the "leaky cell" hypothesis. Presented at the 25th Annual Meeting of the MidSouth Aquatic Plant Management Society, October 24-26, 2006. Orange Beach, Alabama. Dorman, L., J.W. Castle and J.H. Rodgers, Jr. 2007. Performance of a pilot-scale constructed wetland for simulated ash basin water. Presented at the Clemson Hydrogeology Symposium, April 17, 2007. Clemson, SC. lannacone, M., J.W. Castle and J.H. Rodgers, Jr. 2007. Evaluation of equalization basins as initial treatment for flue gas desulfurization waters. Presented at the Clemson Hydrogeology Symposium, April 17, 2007. Clemson, SC. Cross, E., J.W. Castle, G.M. Huddleston and J.H. Rodgers, Jr. 2007. Design and construction, and acclimation of a demonstration-scale constructed wetland treatment system for natural gas storage produced waters. Presented at the Clemson Hydrogeology Symposium, April 17, 2007. Clemson, SC. Bennett, D., J.W. Castle and J.H. Rodgers, Jr. 2007. Boron removal in constructed wetland treatment systems for irrigation waters: A process study. Presented at the Rodgers-64 Clemson Hydrogeology Symposium, April 17, 2007. Clemson, SC. Eggert, D.E., C. Hensman and J.H. Rodgers, Jr. 2007. Performance of Pilot-Scale Constructed Wetland Treatment Systems for Flue Gas Desulfurization Waters. Presented at the 68th Annual International water Conference, Oct. 21-25, 2007. Orlando, FL. C.Murray-Gulde, F.D. Mooney, G.M. Huddleston, III, J.H. Rodgers, Jr. and D. Eggert. 2007. Designing Constructed Wetlands for Mitigating Risks from Flue Gas Desulfurization Wastewater. Presented at the 68th Annual International water Conference, Oct. 21-25, 2007. Orlando, FL. J.H. Rodgers, Jr. 2008. Why Herbicides and Algaecides Kill Plants and Algae and Not Fish. Presented at the 2008 Bassmaster Classic Conservation Workshop. Feb 23, 2008. Greenville, SC. J.H. Rodgers, Jr., B.M. Johnson, V. Molina, and W. Bishop. 2008. Choosing an Efficacious Algaecide: Development of a Decision Support System. Presented at the 28th Annual Meeting of the Midwest Aquatic Plant Management Society. Mar. 1-3, 2008. Sandusky, OH. Bishop, W. and J.H. Rodgers, Jr. 2008. Effective Control of Lyngbya wollei: Variance in Response to Algaecides. Presented at the 28th Annual Meeting of the Midwest Aquatic Plant Management Society. Mar. 1-3, 2008. Sandusky, OH. Rodgers-65 Environmental Reports Referenced in Stanly County's Comment Letter (in disc format)