20150042 Ver 1_Martha Girolami_20150406

Burdette, Jennifer a
From: MARTHA W GIROLAMI <mgirolami @me.com>
Sent: Monday, April 06, 2015 1:04 PM
To: Burdette, Jennifer a; Devane, Boyd
Subject: Fwd: Comments on Green Meadow SAW - 2014 -02254 permit /404 impact permit
Attachments: Comments to the Corps April 6.docx
Begin forwarded message:
From: MARTHA W GIROLAMI <mgirolami(q-)_mac.com>
Subject: Comments on Green Meadow SAW- 2014 -02254 permit /404 impact permit
Date: April 6, 2015 12:32:58 PM EDT
To: Brown Craig < Craig.J.Brown(c�usace.army.mil>
Cc: karen.higgens(a)_ncdenr.gov
Dear Mr. Brown
Thank you for your consideration of these comments.
Martha Girolami
473 Mount Pisgah Church Rd
Apex, NC 27523
919- 362 -5759
1

April 6, 2015
Mr. Craig Brown
U.S. Army Corps of Engineers Regulatory Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
Dear Mr. Brown,
I appreciate your consideration of my comments on the application from Green
Meadows, LLC seeking Department of the Army authorization to discharge fill
material into jurisdictional wetlands and streams associated with coal ash pits to be
located at the Brickhaven and Colon Road Mines in Chatham and Lee Counties, NC.
I live in Chatham County and have closely followed this proposed project by
Duke Energy and Charah /Green Meadows. My interest was provoked because I
oppose the lack of Democracy, i.e. there was no local government involvement and
collaboration in this decision to transport and dispose of millions of tons of coal ash
in my county. Coal ash dumps are being imposed. Also, landfills should not be used
for coal ash residuals and the permits from DENR are weak and fail to protect the
people, environment and many plants and animals living in and around these two
clay mines. The Chatham Board of Commissioners has unanimously passed a
resolution opposing this coal ash dump at Brickhaven.
Air Pollution and the Environment and Health:
Air pollution is a probable danger to the transport routes and the clay mines and
surrounding areas. Considerable tonnage of coal ash will be lost in material
handling and transport. Green Meadows / Charah has no stated plans in its permit to
do its material handling in an enclosed space to prevent dispersion and loss. There
is no air permit. Citizens must rely on only nuisance complaints which may activate
calls to keep the ash damp or some minimal strategy. Loosely tarped trucks and
open rail cars are to be used with no sealed barriers to prevent blow out of ash.
Material handling on site may involve backhoeing ash from rail cars to trucks or to
the ground, dumping ash into mine cells. Both trucks, backhoe and especially
"empty" rail cars will still contain ash that can be released to the air as they move
around the site or return to the Sutton and Riverbend plants to be refilled.
Since the fly ash portion of the coal ash residuals is low micron or submicron in size,
it is very difficult to prevent dispersion over the countryside and to confine in any
type of windy conditions or during the motion of transportation by rail or truck. To
illustrate how coal ash is readily dispersed and released by Duke Energy or
subcontractors, a few examples are given below.
On April 3, 2015, two photos taken by a resident of the Brickhaven area on Corinth
Road are attached. These show the air pollution from coal ash dust clouds coming
off of the pond at the inactive Cape Fear power plant.
Charah is causing significant pollution currently from trucking coal ash from the
Duke Energy Asheville power plant to its Asheville airport coal ash construction fill

project several miles down a rural highway. On February 4, 2015 a reporter with
WSOTV in Charlotte interviewed a landowner along this road. He said that trucks
drive by every two minutes and that "ash from the trucks has turned the road gray"
and that to cut his grass "you have to wear a mask. The whole side of the road ...it's
dust." The link below is to the article and video about this air pollution.
http:././www.wso ctv.com/news/news/sp ecial-rep orts.19 -investigates- coal-ash-
cleanup -problems.Inj 4j 41
April 3, 2015: photos taken of coal ash air pollution blowing from the Cape Fear

In "Ash in Lungs: How Breathing Coal Ash is Hazardous to Your Health"
released by Physicians for Social Responsibility and Earthjustice, the authors state
that coal fly ash which is less than 2.5 microns in size, is able to go deep into your
lungs. These particles are known to cause heart disease, asthma, stroke and
COPD as well as silicosis (like asbestosis) and cancer. Also these dust particles
contain toxic heavy metals and often radioactivity which are often carcinogens and
neurotoxins. Almost all toxins to humans are toxic to wildlife as these metals
become incorporated into their environment and food or are breathed in or pass
through skin or membranes to damage health and viability.
http: /Iearthjustice.org/news/press/ 2014 / ash -in- lungs- how - breathing- coal - ash -is-
hazardous -to -your- health
In summary, material handling combined with winds and poor practices can
broadcast coal fly ash over many miles around the Brickhaven and Colon Road
projects and all transport routes. Material handling has low standards, is not
enclosed and regulations are minimal. Air pollution from coal ash is already
impacting the target area in Chatham and other sites in NC. Toxicity is from the
particle size which passes into the lung's aveoli, from metal toxicity and from
radioactivity. The coal ash air pollution constitutes irreversible and permanent
harm to environment and health.
Project Size and Scope:
The DENR permits call for 11.5 million Tons maximum storage of ash at the
Brickhaven mine and 9 million Tons at Colon Road mine. However, the third page of
the Green Meadows permit application (SAW- 2014 - 02254) under Project
Description states that "Approximately 3 million tons of coal ash would be
transported to the Brickhaven and Sanford Mines for use in mine reclamation." This
is a serious difference in project size and impact. This discrepancy must be resolved
since certainly the scale of the project is a fundamental consideration for your
decision.
Liability Transfer and Commercial Enterprise
Duke Energy has transferred liability to Charah /Green Meadows for all
environmental impacts that may occur at the coal ash dumps at the clay mines
for the next 30 years. By buying the services of Charah /Green Meadows, Duke
Energy which has enormous financial resources, is no longer responsible for its own
coal ash wastes. Green Meadows as a limited liability corporation has minor cash
reserves and assets. Also, by making the landfill /mine reclamation a commercial
enterprise, by the laws of interstate commerce, the business must accept coal ash
from outside the state of NC and from other companies besides Duke Energy in NC.
Brickhaven and Colon Road will likely be new Superfund sites in 30 years and the
finger pointing and blame game between these parties will prevent real and timely
(if indeed this is possible) remediation actions.

Groundwater and Clean up:
The clean up moneys /bonds etc. are inadequate for a clean up if /when leaks occur
in the linings. The DENR permit requires that only $2 million be set aside by Green
Meadows for correction action for spills and leaks. Plastic liner manufacturers have
no real knowledge of how long their liners will last. Email inquiries into liner HDPE
liner longevity produced two longevity estimates of 5 and 20 years. But the coal ash
and its toxic metal composition are forever. Also once a leak is detected, since the
ash is buried in a large cell and is partially underground, how is it possible to find
where the leak is and repair it? It cannot be done. All that can be done is watch the
plume grow and put homes /farms on county water if available. Rivers and streams
and the wildlife that depend on them receive this burden of pollution.
Above Ground Storage
Coal ash should be mixed with concrete and stored in above ground containment
as discussed in the following article. Of course these storage bunkers must be sited
at the source power plant. Two wrongs don't make a right. Dumping ash in unlined
riverside pits at the power plants (first wrong) and dumping this coal ash 200+
miles away in Brickhaven and Colon Road (second wrong) do not make a right. The
more than 100 million tons of coal ash at power plants across NC must be disposed
of in above - ground bunkers at the source power plant and must NOT be transported
across the state to Brickhaven and Colon Road mines. This salt -stone technology
is discussed in this article.
http: / /www.bredl.org/pdf4 /Coal ash report 14 -083 w ARpx A +B.pdf
Selenium and HDPE Liners:
Dr. A. Dennis Lemly, Research Fish Biologist with the USDA Forest Service and
Department of Biology at Wake Forest University raises concerns that landfill liners
and membranes are permeable to anions of selenium and points out that there are
no "post closure data and no selenium measurements at all" in coal ash landfill
performance applications. He reviews the toxicity of selenium, its high
concentration in coal ash leachate and that "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."
Dr. Lemly discusses an EPA report that states that "leakage through properly
constructed HDPE GM primary liners that have undergone CQA monitoring will
occasionally be in excess of 200 Lphd (liters per hectare per day) during active
period of operation and up to 200 Lphd during post closure period." He states
this may constitute an environmental hazard with "biological significance ".
He goes on to evaluate this release saying that unless there is more than a 1000 fold
dilution factor of the released leachate, containing a typical coal ash leachate
concentration of selenium of 2000 microgram per liter, then the concentration of
polluted water could be as much as 2 micrograms per liter. This concentration is
toxic to fish and wildlife.
There is no data that says a HDPE or any other type of membrane liner

will not be permeable to certain anions specifically toxic selenium. This reliance on
landfills and liners for coal ash residuals is not based on science or experience. As
discussed in the previous section, the only safe storage of coal ash residuals is in
above ground concrete bunkers using the salt stone technology.
Reference: Lemly, A.D. 2010. Technical and Environmental Issues with Synthetic
Liners Proposed for use in Coal Ash Disposal Applications. Technical Report to
USEPA Available from the Author at the Department of Biology, Wake Forest
University, Winston- Salem, NC 27109.
The Need for a Hearing on the Green Meadows Permit:
Since each citizen is allowed only 3 minutes to communicate to the hearing officers
information, criticism and suggestions on the proposed Coal ash dumps in
Brickhaven and Colon Road and since there are three permits being commented on
in two meeting of three hours each, I do not think this is enough time. It is very
unusual to have more than one permit commented on at a hearing. People need
time to tell their stories, to describe their concerns. Some can spit out opinions
in seconds and others need more time.
Also, this accelerated process of coal ash clean up is mandated by the NC Legislature
in its Coal Ash Management Act. There has never been a decree like this before.
DENR has been under heavy and unsuitable pressure to create permits for
a landfill type project based on very little time and scant environmental information.
Normally a landfill permit will require over two years to complete but this permit
has been developed in less than a year. Concerned citizens need to have a say on
this one permit, not diluted or confused with the DENR permits.
Due to the many significant and irreversible environmental risks of this permit
application by Green Meadows, in my view, it should not be approved.
Thank you
Martha Girolami
473 Mount Pisgah Church Rd
Apex, NC 27523
Chatham County
919 - 362 -5759