20150041 Ver 1_Pre-Notice Comments_20150220

Burdette, Jennifer a
From:
Keely Wood <keely @bionaturae.com>
Sent:
Friday, February 20, 2015 10:47 AM
To:
Lorscheider, Ellen; Ali, Haris; Barber, Jim; Bernard, Jane; Bolich, Rick; Burdette, Jennifer
a; Cantwell, Janet; Clark, Allen; Coburn, Chad; Corporon, Joe; Deberardinis, Jeff; Deck,
Erin M; Dunlap, Billy A; Garoma, Miressa; Giorgino, John; Hardy, Allen; Harris, Dwight;
Hill, Tammy; Holland, Victor; Karoly, Cyndi; Kiley, Andrew R; Kinney, Maureen; Knies,
Sara V; Kreiser, Gary; Love, Barry F; Maher, Niki; Manuel, Vanessa; Marble, Robert;
Mcguire, Sean; Mcnees, Jamie; Mcnutt, Cam; Merritt, Katie; Milosh, Ray; Morris, Eric B;
Owen, Debra; Painter, Andy; Pointer, Brian; Price, Zan (George); Ridings, Rob; Savage,
Rick; Scarbraugh, Anthony; Scheller, Roberto; Smith, Cherri L; Smith, George; Towell,
Buster; Ventaloro, Christopher; Wiggins, Mack; Zhang, Cheng; Zhang, Cheng
Cc:
gilliand.houston @epa.gov; Robert.Reives @ncleg.net; Brad.Salmon @ncleg.net
Subject:
Liner expert and why Coal ash should not be DUMPED on Lee & Chatham County NC
Attachments:
Lemly -Se and Line rs- review. pdf, ATT0001O.htm
Good Morning;
To all the DENR environmentalists "specialist ". Is there someone at DENR that has common sense next to their "titles"
Mr. Lemly has over 30 years of working with coal ash residues and pollution. He Prepared a report for the EPA on liners and
coal ash. See attached
A. Dennis Lemly, Ph.D.
Research Fish Biologist
USDA - Forest Service, Southern Research Station
Piedmont Aquatic Research Laboratory
Department of Biology, Wake Forest University, Winston - Salem, NC
dlemly @fs.fed.us, 336- 758 -4532
Please do not approve the recent permit application by Charah as a "mine reclamation" to move coal ash into Lee and Chatham
County.
They are planning on placing it right on top of our water shed area and there are 2000 homes within one half mile of this
proposed dump site.
8 million tons placed in a 140 acre area will create a 5 story mountain, and never be brought back to "it's natural topography ".
Call Lee County GIS dept Don Kovashitz if you want a lesson on true GIS reporting and not the lies in the permit.
Duke needs to recycle what they can, and keep it on their own property, encapsulated. Would you want a coal ash dump near
your home? Knowing all you do would you move? Keep the coal ash where it is, instead of dragging it all over the state.
Check your privilege
Keely Wood
919- 708 -5221

Technical and Environmental Issues with Synthetic Liners Proposed for use in Coal Ash
Disposal Applications
A. Dennis Lemly, Ph.D.
Research Fish Biologist
USDA - Forest Service, Southern Research Station
Piedmont Aquatic Research Laboratory
Department of Biology, Wake Forest University, Winston - Salem, NC
dlemly @fs.fed.us, 336- 758 -4532
Prepared for U.S. Environmental Protection Agency
Office of Resource Conservation and Recovery
Washington, DC
EPA Docket ID No. EPA— HQ —RCRA- 2009 -0640
Hazardous and Solid Waste Management System:
Identification and Listing of Special Wastes:
Disposal of Coal Combustion Residuals from Electric Utilities — Proposed Rule
September 21, 2010

CBDL HSPVOE!
The USEPA is holding a total of 8 hearings on classification and disposal of coal combustion
residuals (CCRs) prior to completing and issuing its final rule (1). The Geosynthetic Materials
Association (GMA) was among the first in line to address the issue on August 30 at the initial
hearing in Arlington, VA, and will deliver similar testimony at each of the other hearings as well.
GMA has long maintained a position that CCRs can be safely contained as solid waste and that a
designation as special waste (hazardous waste) would be overkill. However, regardless of the
designation EPA makes, it is becoming clear that through advocacy efforts by GMA and others,
the use of Geosynthetic Membrane (GM) liner systems that use High Density Polyethylene
(HDPE) as the primary liner material will likely be required in the disposal of coal ash waste.
GMA has posted several written comments on this issue. (The complete set of GMA's
comments can be found at: http : / /geosyntheticsmagazine.com /news /gmaupdate). In addition
to the public hearings and written comments, GMA bolstered support for geosynthetic lining of
coal ash sites during Capitol Hill meetings with U.S. House and Senate staffs during GMA's
Lobby Day activities on September 15.
Following are the comments made by GMA members during the August 30 EPA hearing in
Arlington, just outside Washington, D.C.:
Today 1 am representing the Geosynthetic Materials Association, the trade group of 80
companies that manufacture, distribute and install geosynthetic materials, including liners
systems. The industry employs 12,000 people throughout the United States.
Our comment to EPA is very simple. We request that EPA mandate the geosynthetic lining of
coal ash storage facilities using composite lining systems. In the shortest terms, use liners,
specifically composite liners.
Why? Because liners work. Concerns of safety regarding CCRs are mitigated if the landfill
storage sites are lined with a composite liner system of a geomembrane and a geosynthetic clay
liner. A composite liner system prevents the leachate from entering the environment. Safety
concerns regarding surface impoundments are also mitigated if the impoundments are lined
with a composite liner system.
The American Society of Civil Engineers does a regular "Report Card on America's
Infrastructure. "For the last three report cards, representing over a decade, solid waste has
received the highest grade of any category. My industry does a good job of taking America's
waste and properly storing it to protect the environment. The materials, technology and people
exist [now] —the engineers, engineering techniques and standards, the general contractors and
installers who can build the proper facilities and the regulators and inspectors who assure the
work is done correctly. We urge EPA to "use what exists and is working today."

Further, our industry has continuously improved over time and EPA has been a part of that
effort. Over the years, EPA has commissioned nearly 80 studies of the design and performance
of lining systems. We specifically call your attention to a 2002 study titled "Assessment and
Recommendations for Optimal Performance of Waste Containment Systems" (EPA 600/R-
021099). That study contains a great deal of pertinent information on how to construct
containment systems. Most illustrative for today is a graph charting the leakage rate of
different designs over the life cycle of nearly 200 facilities. The composite liner system of a
geomembrane and a geosynthetic clay liner was demonstrated to have the lowest leakage rate
over all life cycle stages, including a near zero leakage rate after the facilities are closed and
final cover placed. Our materials work.
Use of composite liner systems will achieve the EPA mission to protect human health and the
environment for all Americans.
A brief word on the hazardous /non- hazardous question. While coal ash does contain heavy
metals, it lacks the traditional characteristics of hazardous materials, radioactivity or the
presence of infectious medical waste, etc. In the opinion of our trade organization, coal ash can
be properly stored using subtitle "D" regulations, a non - hazardous solid waste designation with
composite liner systems.
Thank you.
In addition to the above italicized comments delivered in oral testimony, the GMA website
includes this chart and following legend as evidence of liner performance:
Chart courtesy of the Geosynthetic Research Institute (GRI) at Drexel University.
GemembraneOCIL
G141 l- Composite finier
2
zoo
01
of sites t type)
Q
)
T�
Initial
Sobsmuent Aflar
Filhng
Filling Final Co
Lie Cycle Stage

Waste disposal sites in the U.S. -199 total —with a variety of designs and materials were
examined. The survey population included sites at different phases of the site lifespan as
indicated on the "X" axis. The site leakage (collection) rate was plotted on the "Y" axis for the
three types of liner design: yellow – geomembrane alone, green – geomembrane and compacted
clay, red –a geomembrane and GCL (geosynthetic clay liner) composite liner system. The key
point is the optimal performance of the composite liner system(s), including a near zero leakage
rate for the closed ( "After Final Cover ") site.
Data Source: Bonaparte, Daniel, and Koerner. (2002) "Assessment and Recommendations for
Optimal Performance of Waste Containment Systems," EPA /600 /R- 02/099. U. S. EPA, ORD,
Cincinnati, OH
ISSUE WITH GMA POSITION
I am not an expert in GM liner performance but I do know a fair bit about selenium as a water
pollutant from coal ash, the threat it poses to fish and wildlife health, and the importance of
proper disposal techniques in mitigating that threat. Selenium is a trace element that leaches
out of CCRs, bioaccumulates in aquatic food chains, and causes deformed young, reproductive
failure, and other toxic effects. I have studied the environmental toxicology of selenium as a
water pollutant from CCRs for over 30 years and published 47 research papers and a reference
book on selenium sources, environmental cycling, and toxic impacts (see attached technical
qualifications). My investigations of CCR impacts span the country, beginning with the
landmark pollution event at Belews Lake, North Carolina in the 1970's, which eliminated 19
species of fish, and continuing today, with the on -going catastrophe from the TVA ash spill in
Tennessee, which has polluted an entire river ecosystem and elevated tissue concentrations of
selenium in fish to levels that cause massive reproductive failure.
After hearing the testimony of GMA members and seeing the confidence they expressed in the
ability of liners to control coal ash pollutants, I investigated further by reading the reference
they cited as the primary support for their position (EPA /600 /R- 02/099).
In the course of my initial review I found that liner performance results in GMA's cited data
source did not measure up to the level of reliability and confidence they had espoused in their
written and oral statements. For example, selenium was not measured in the leachate from the
single coal ash disposal site studied (out of 199 sites), or any other for that matter. The report
did state that the leachate rate was 300 -600% greater for the coal ash site than other waste
types, which suggested to me that post - closure data is critical to evaluate the performance of
GM materials in the context of what GMA was saying about EPA's proposed rule, i.e., that
composite liners will protect people and the environment. Yet, there was no post - closure data
for the coal waste site. This led me to question GMA's position and whether they could
reasonably (accurately) project performance for a HDPE primary liner in a coal -ash application
when there is (1) no post - closure data and (2) no selenium measurements at all in their key
reference citation. I am a generally a proponent of liners and I believe they are a step in the
4

right direction. However, what GMA presented, based solely on the EPA 2002 study, was not
convincing or conclusive with respect to coal ash and selenium. The lack of information on
mobility and containment of selenium seemed to rise to the level of a fatal flaw in GMA's
analysis and statements about a GM liner's ability to protect the environment.
FURTHER ANALYSIS
I voiced the above concerns to GMA by posting a reply in the comment forum of their website
on September 13. One of their members responded with the following:
"The performance of liner systems is typically not —in fact, almost never — evaluated
against specific agents (i.e., selenium).
The interaction of geosynthetic liner materials to an extremely wide range of chemicals
is well -known and understood. There is one general class of chemical (very low
molecular weight halogenated hydrocarbons) where there are measurable interaction
differences between the chemical and the geosynthetic material, depending on the
specific nature of the chemical.
For all other general classifications of chemical interactions, the performances of the
geosynthetics are relatively uniform. Thus, testing is not done for a specific chemical.
In fact, it is thought that mixtures of a wide range of chemical components present a
more difficult performance standard for geosynthetic barriers. That is why, during the
early use of geosynthetics, a large number of tests were conducted using leachate from
waste containment facilities, which contained a broad range of chemical constituents.
These tests, identified under the name EPA 9090, have successfully demonstrated the
inertness to a broad range of chemicals that has allowed geosynthetic materials such as
high- density polyethylene to contain materials effectively for decades ".
This response was not sufficient to allay my concerns and I continued my analysis of the liner
performance issue by examining the EPA 9090 studies and other performance information.
Following this analysis I posted the following reply on GMA's website on September 16:
"I am not concerned about selenium interacting with the membrane and degrading it,
which is what EPA 9090 examines (compatibility). I want to know if there are
permeability issues for the oxyanion and organic forms of selenium (selenate, selenite,
selenomethionine, hydrogen selenide, etc.). Specifically, are there (1) laboratory studies
showing that permeation or co- transport of selenium and water do not occur in the
long -term (months - years) when the membrane is exposed to whole -ash leachate, and
(2) field monitoring studies to confirm that none of these forms is passing through and
getting into groundwater or surface water at concentrations of concern to fish and

wildlife health ( >1 ug /L) during the operational life of a lined coal ash landfill or surface
impoundment, and 1, 5, 10 etc. years after closure. It would also be very useful to know
the volume of leachate that is contained by the liner during the same period, as well as
its Se concentration. The 1984 EPA 9090 tests and many others since then were
conducted with industrial or municipal waste leachate that contained <5 ug /L Se.....coal
ash leachate can have >20,000. Unless there are lab and field performance studies
available which show satisfactory results, it is, at best, misleading for a GMA
spokesperson to appear at an EPA hearing on coal ash disposal and contend that "our
liners work" with respect to selenium pollution. You can't credibly say they work if you
can't demonstrate that they work. This demonstration has apparently not been done for
selenium. I hope your last statement, i.e., that geosynthetic materials have effectively
contained materials for decades, will prove true for selenium and coal ash, but I see no
current evidence or proof of this in the trade, scientific, or regulatory literature. Are
there others within your industry that have additional information that would be useful
in answering my questions ? ".
LATEST DEVELOPMENTS AND CONCLUSIONS
As of September 21, GMA has not responded to my latest comment, but I have continued to
study the liner issue and I have discovered an even more disturbing set of circumstances that I
wish to bring to the attention of EPA. Data in the 2002 EPA report seem much less supportive
of GMA's statements about liner performance than they would have you believe. For example,
13 cells with GM /CCL or GM /GCL /CCL composite liners were monitored (Table 5 -6, pages 5 -25 —
5 -30), none of which was a coal ash disposal cell. Only 5 produced sufficient data for a
conclusion about leakage and overall performance. Four were deemed effective and one began
to fail after only 12 months due to "breakthrough" of the diagnostic constituents sulfate and
chloride which, like selenium, are anions. The report states (page 5 -31) "The reason for the
increase in the anion concentrations in the LDS (Leak Detection System) flow from Cell AD7 is
unclear ". This "unknown" leaves open the question I raised about selenium movement through
liners, and is particularly troubling in light of the fact that Cell AD7 is part of a facility that was
built, operated, and closed under Construction Quality Assurance (CQA) monitoring for a Class
IV Hazardous Waste Landfill. Moreover, diagnostic organics (toluene, benzene, xylene) did not
exhibit "breakthrough ", indicating that liner failure cannot be attributed to tears, holes, or
some other physical failure that allowed whole -waste leachate to pass through. Also, anionic
forms of selenium are known to interact with High Density Polyethylene (2), the predominant
constituent of synthetic liners, which could facilitate their passage through this membrane
material. Finally, the combined sulfate - chloride concentration of overlying whole -waste
leachate was much greater in the failed cell than in 3 of the 4 intact cells (16, 864 mg /L vs. 201,
341, 821; Table E -4 -9), suggesting that anionic strength of the leachate may have been a factor
contributing to liner failure. Coal ash produces leachate with an exceptionally high anionic
strength due to the presence of sulfate, chloride, and many other constituents. Sulfate
concentrations alone can exceed 30,000 mg /L (3). Moreover, ammoniated coal ash, which is
the predominant form produced today, enhances the leaching rate of elements that form

anionic compounds in solution, in particular, selenium, arsenic, molybdenum, fluoride, and
vanadium (4). Collectively, these factors suggest that failure of HDPE liner material in a coal ash
application is very possible for chemical reasons unrelated to direct degradation of the
membrane itself. The EPA report goes on to state (page 5 -32) "The conclusions for composite
liners should be considered preliminary. Additional analyses are recommended ....... the
additional analyses should include a more thorough analysis of the transport characteristics of a
wider array of key chemical constituents than considered in this study ". The 2002 EPA report
confirms my suspicion that the behavior of selenium is largely unknown and untested for
composite liner systems. What the EPA report shows is alarming - -- a 20% failure rate. If you
project that to the multitude of lined coal ash waste sites that are /will be in existence, it is easy
to see my concerns. With respect to selenium pollution, GMA's remarks may be leading to a
false sense of security and complacency. In fact, it is likely that a patchwork of ticking time
bombs is being created, some of which have already exploded, some of which will explode in
the near future, and some of which will explode in the long term. GM composite liners may not
be the cure -all suggested by GMA's rather bold statement "Use of composite liner systems will
achieve the EPA mission to protect human health and the environment for all Americans ". EPA's
call for additional monitoring and assessment is well founded. Proper ground and surface
water monitoring studies would reveal the true extent of existing and potential problems, but
they apparently don't exist.....yet. Until this information is available, it is imperative that GMA
stick to facts when discussing the utility of GM liners in the context of an EPA hearing or other
forums. Their effectiveness for coal ash disposal is currently unverified and questionable.
Also, the EPA report brings up another important issue..... "engineering significance" versus
"biological significance ". Regarding the intact cells, it is stated on page 5 -31 that "leachate
migration into the LDS at a rate of any engineering significance has not occurred ", and
concludes on page E -128 that "leakage through properly constructed HDPE GM primary liners
that have undergone CQA monitoring will occasionally be in excess of 200 Lphd during the
active period of operation and up to 200 Lphd during the post - closure period ". The engineering
significance of this leakage rate may not be a concern, but the environmental hazard may be.
Consider, for example, that a 200 Lphd leak for a 25 ha landfill will produce 5,000 liters per day,
or about 1,300 gallons. If that liquid contains a typical coal ash leachate concentration of
selenium (2,000 ug /L, 5), and assuming a dilution factor of 1000 is achieved in groundwater or
surface water (which would require uniform mixing and percolation of the leak water through 3
feet of saturated soil underlying the landfill (7), assimilation by 40 acre -feet of impounded
surface water, or incorporation into a 2 cfs surface stream flow), then the result is 1,300,000
gallons of ambient water per day containing 2 ug Se /L, a concentration that poses a toxic threat
to fish and wildlife (6). This is a tremendous volume of polluted water, amounting to more than
the total daily wastewater flow from a typical town of about 10,000 people (8, 9). If 1000 -fold
dilution is not achieved, Se levels will be higher and pose an even greater risk. Thus, what
constitutes engineering success may not equate to environmental success. Based on the
material I have reviewed, the only scientifically and environmentally credible conclusion is that
HDPE liners won't necessarily solve, or effectively lessen, selenium pollution problems from
disposal of coal combustion residues. If EPA has information generated since their 2002 study

indicating otherwise, it should be made available for external public review, assessment, and
comment prior to final rulemaking.
References
(1) h_ttp: / /www.epa.gov/ wastes /nonhaz/ industrial / special / fossil /ccr- rule /ccr- hearing.htm
(2) h_ ttp:// www. springerlink .com /content /j3u3h927u5188443/
( 3)_ h_ ttp: / /www.cses.vt.edu /revegetation/ Papers% 20PDF/ CCP %20Files %20for %20Web /Publicati
ons/ Stewart.% 20B. R..% 20W. L.% 20Daniels %20and %20M.L. %20Jackson. %201997. %20 Evaluation
%20of 9/o20leachate %20q ua I ity. pdf
(4) http: / /www.flyash.info /2003 /81has.pdf
(5) http:/ /pubs. acs .org /doi /abs/10.1021/ef900044w
(6) Lemly, A.D. 2002. Selenium assessment in aquatic ecosystems: A guide for hazard
evaluation and water quality criteria. Springer- Verlag, New York.
(7) http:/ /www. noble. org /ag/ Soils/ SoilWaterRelationships /Index.htm
(8) http://www.archdale-nc.gov/ index. asp? Type =B_ BASIC &SEC= 19534B7F5- 399B- 4EC9 -8754-
C41389A2C503}
(9) http:/ /www. city- data.com / city /Archdale- North- Carolina.html
TECHNICAL QUALIFICATIONS STATEMENT OF DR. A. DENNIS LEMLY
I have spent over 30 years investigating the effects of aquatic pollution from coal combustion residues
(CCR). I have extensive experience conducting field and laboratory research on selenium, which is one
of the most toxic trace elements in CCR. My studies have focused on aquatic cycling, bioaccumulation,
and effects on fish. These studies include intensive investigation of two of the most substantial cases of
selenium pollution that have taken place in the USA: (1) Belews Lake, North Carolina, where 19 species
of fish were eliminated due to selenium in CCR, and (2) Kesterson Marsh, California, where thousands of
fish and aquatic birds were poisoned. My career began in the 1970's with studies of the landmark
pollution event at Belews Lake, which established the fundamental principles of selenium
bioaccumulation and reproductive toxicity in fish resulting from CCR. In the 1980's, I was a research
project manager for the U.S. Fish and Wildlife Service, directing studies that determined impacts of
selenium from agricultural irrigation drainage on fish and aquatic birds at Kesterson and in 14 other
western states. In the 1990's, the emphasis of my research shifted to the development of methods and
I3

guidelines for hazard assessment and water quality criteria for selenium, which led to the publication of
a reference book (see item 42 below). This handbook contains the first comprehensive assessment tools
for evaluating selenium pollution from CCR on an ecosystem scale. I have consulted on selenium
contamination issues ranging from CCR landfill leachate in Hong Kong to mountain top removal coal
mining in West Virginia. I provide the methods and technical guidance necessary to identify, evaluate,
and correct aquatic selenium problems before they become significant toxic threats to fish and wildlife
populations. I have Masters and Doctorate degrees in biology from Wake Forest University.
PUBLICATIONS ON SELENIUM TOXICITY FROM COAL COMBUSTION RESIDUES, COAL MINING, AND
OTHER SOURCES:
1. Lemly, A.D. 1982. Response of juvenile centrarchids to sublethal concentrations of waterborne
selenium: I. Uptake, tissue distribution, and retention. Aquatic Toxicology 2: 235 -252.
2. Lemly, A.D. 1982. Determination of selenium in fish tissues with differential pulse polarography.
Environmental Technology 3: 497 -502.
3. Lemly, A.D. 1983. A simple activity quotient for detecting pollution- induced stress in fishes.
Environmental Technology 4: 173 -178.
4. Lemly, A.D. 1985. Ecological basis for regulating aquatic emissions from the power industry: The
case with selenium. Regulatory Toxicology and Pharmacology 5: 465 -486.
5. Lemly, A.D. 1985. Toxicology of selenium in a freshwater reservoir: Implications for environmental
hazard evaluation and safety. Ecotoxicology and Environmental Safety 10: 314 -338.
6. Lemly, A.D. 1986. Effects of selenium on fish and other aquatic life. Pages 153 -162 in J.B. Anderson
and S.S. Anderson, editors. Toxic Substances in Agricultural Water Supply and Drainage: Defining the
Problems. U.S. Committee on Irrigation Drainage, Denver, CO.
7. Lemly, A.D., and G.J. Smith. 1987. Aquatic Cycling of Selenium: Implications for Fish and Wildlife.
Fish and Wildlife Leaflet 12. U.S. Fish and Wildlife Service, Washington, DC. 10 pages.
8. Lemly, A.D. 1989. Cycling of selenium in the environment. Pages 113 -123 in A.Q. Howard, editor.
Selenium and Agricultural Drainage: Implications for San Francisco Bay and the California Environment.
The Bay Institute of San Francisco, Tiburon, CA.
9. Lemly, A.D., and G.J. Smith. 1991. Selenium in aquatic ecosystems: Potential impacts on fish and
wildlife. In R.C. Severson, S.E. Fisher, Jr., and L.P. Gough, editors. Proceedings of the Billings Land
Reclamation Symposium on Selenium in Arid and Semiarid Environments, Western United States. U.S.
Geological Survey Circular 1064: 43 -53.
10. Lemly, A.D. 1993. Subsurface agricultural irrigation drainage: The need for regulation.
Regulatory Toxicology and Pharmacology 17: 157 -180.
11. Lemly, A.D., S.E. Finger, and M.K. Nelson. 1993. Sources and impacts of irrigation drainwater
contaminants in arid wetlands. Environmental Toxicology and Chemistry 12: 2265 -2279.
12. Lemly, A.D. 1993. Guidelines for evaluating selenium data from aquatic monitoring and
assessment studies. Environmental Monitoring and Assessment 28: 83 -100.
13. Lemly, A.D. 1993. Teratogenic effects of selenium in natural populations of freshwater fish.
Ecotoxicology and Environmental Safety 26: 181 -204.
E

14. Lemly, A.D. 1993. Metabolic stress during winter increases the toxicity of selenium to fish. Aquatic
Toxicology 27: 133 -158.
15. Lemly, A.D. 1994. Agriculture and wildlife: Ecological implications of subsurface irrigation drainage.
Journal of Arid Environments 28: 85 -94.
16. Lemly, A.D. 1994. Irrigated agriculture and freshwater wetlands: A struggle for coexistence in the
western United States. Wetlands Ecology and Management 3: 3 -15.
17. Lemly, A.D. 1995. A protocol for aquatic hazard assessment of selenium. Ecotoxicology and
Environmental Safety 32: 280 -288.
18. Lemly, A.D. 1996. Selenium in aquatic organisms. Chapter 19 (pages 427 -445) in W.N. Beyer, G.H.
Heinz, and A.W. Redmon- Norwood, editors. Environmental Contaminants in Wildlife: Interpreting
Tissue Concentrations. Lewis Publishers, Boca Raton, FL.
19. Lemly. A.D. 1996. Winter Stress Syndrome: An important consideration for hazard assessment of
aquatic pollutants. Ecotoxicology and Environmental Safety 34: 223 -227.
20. Lemly, A.D. 1996. Identifying and reducing environmental risks from agricultural irrigation drainage
in developing countries. Proceedings of the World Congress of Toxicology in Developing Countries 3:
177 -190.
21. Lemly, A.D. 1996. Assessing the toxic threat of selenium to fish and aquatic birds. Environmental
Monitoring and Assessment 43: 19 -35.
22. Lemly, A.D. 1996. Wastewater discharges may be most hazardous to fish during winter.
Environmental Pollution 93: 169 -174.
23. Lemly, A.D. 1996. Evaluation of the hazard quotient method for risk assessment of selenium.
Ecotoxicology and Environmental Safety 35: 156 -162.
24. Lemly, A.D. 1997. Ecosystem recovery following selenium contamination in a freshwater reservoir.
Ecotoxicology and Environmental Safety 36: 275 -281.
25. Lemly, A.D. 1997. Environmental hazard of selenium in the Animas La Plata Water Development
Project. Ecotoxicology and Environmental Safety 37: 92 -96.
26. Lemly, A.D. 1997. Role of season in aquatic hazard assessment. Environmental Monitoring and
Assessment 45: 89 -98.
27. Lemly, A.D. 1997. A teratogenic deformity index for evaluating impacts of selenium on fish
populations. Ecotoxicology and Environmental Safety 37: 259 -266.
28. Lemly, A.D. 1997. Environmental implications of excessive selenium. Biomedical and
Environmental Sciences 10: 415 -435.
29. Lemly, A.D. 1998. Pathology of selenium poisoning in fish. Chapter 16 (Pages 281 -296) in W.T.
Frankenberger and R.A. Engberg, editors. Environmental Chemistry of Selenium. Marcel- Dekker Press,
New York, NY.
30. Lemly, A.D. 1998. A position paper on selenium in ecotoxicology: A procedure for deriving site -
specific water quality criteria. Ecotoxicology and Environmental Safety 39: 1 -9.
31. Lemly, A.D. 1998. Belews Lake: Lessons learned. Pages 3 -6 and E15 -20 in U.S. EPA Publication EPA -
822 -R -98 -007. Report on the Peer Consultation Workshop on Selenium Aquatic Toxicity and
Bioaccumulation. U.S. Environmental Protection Agency, Office of Water, Washington, DC.
32. Lemly, A.D. 1999. Case study: Contaminant impacts on freshwater wetlands at Kesterson National
10

Wildlife Refuge, California. Chapter 6 (pages 191 -206) in M.A. Lewis et al., editors. Ecotoxicology and
Risk Assessment for Wetlands. SETAC Press, Pensacola, FL.
33. Lemly, A.D. 1999. Selenium transport and bioaccumulation in aquatic ecosystems: A proposal for
water quality criteria based on hydrological units. Ecotoxicology and Environmental Safety 42: 150 -156.
34. Lemly, A.D. 1999. Irrigation drainage. Pages 304 -307 in M.A. Mares, editor. Encyclopedia of
Deserts. University of Oklahoma Press, Norman, OK.
35. Hamilton, S.J., and A.D. Lemly. 1999. The water - sediment controversy in setting environmental
standards for selenium. Ecotoxicology and Environmental Safety 44: 227 -235.
36. Lemly, A.D. 1999. Selenium impacts on fish: An insidious time bomb. Human and Ecological Risk
Assessment 5: 1139 -1151.
37. Lemly, A.D., R.T. Kingsford, and J.R. Thompson. 2000. Irrigated agriculture and wildlife
conservation: Conflict on a global scale. Environmental Management 25: 485 -512.
38. Lemly, A.D. 2001. Irrigation- induced demise of wetlands. Pages 399 -410 in R.E. Munn and I.
Douglas, editors. Global Environmental Change, Volume 3: Causes and Consequences of Global
Environmental Change. John Wiley & Sons Ltd., Chichester, United Kingdom.
39. Lemly, A.D. 2002. Symptoms and implications of selenium toxicity in fish: The Belews Lake case
example. Aquatic Toxicology 57:39-49.
40. Lemly, A.D., and H.M. Ohlendorf. 2002. Regulatory implications of using constructed wetlands to
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