The URL can be used to link to this page

Home My WebLink About20150042 Ver 1_John Wagner_20150516Burdette, Jennifer a From: john_wagner @sarbo.net Sent: Saturday, May 16, 2015 11:18 AM To: SVC_DENR.publiccomments Subject: DEMLR Attachments: Public Comments on Duke Permits May 2015.pdf Attached are my comments on: The State Mining and Structural fill (coal ash) permits for Brickhaven Mine Tract "A" Site and Colon Road Mine Site. Please let me know if you receive this email and the attachment. Thank you, John Wagner 210 Jessamine Lane Pittsboro, NC 27312 #Oq§@9D4R4&Y3@2P"§) 10,§ No Oq#CP &040 ::5 )0$ 9 AD 9L . .o. .o Comments on the State Mining and Structural fill (coal ash) permits for Brickhaven Mine Tract "A" Site and Colon Road Mine Site John Wagner May 16', 2015 4 °¢ 0R#0%6jU-> 92 That the operation will have unduly adverse effects on potable groundwater supplies, wildlife, or fresh water, estuarine, or marine fisheries; ................................................................ ............................... 3 HDPE Liners for Coal Ash Dumps ........................................................................ ............................... 3 Tearingand Punctures .................................................................................... ............................... 3 Cracking............................................................................................................ ............................... 4 MicrobialBreakdown ....................................................................................... ..............................7 pHControls ...................................................................................................... ............................... 8 GulfCreek Wetlands ............................................................................................... ..............................9 Wildlife.................................................................................................................. .............................12 NorthernLong Eared Bat ............................................................................... .............................12 CapeFear Shiner ............................................................................................. .............................14 Otherthreatened wildlife ................................................................................... .............................16 93 That the operation will violate standards of air quality, surface water quality, or groundwater quality that have been promulgated by the Department; ....................................................... .............................18 Toxins.................................................................................................................... .............................18 Hexavalent Chromium (or Cr(Vl) ) .............................................................. .............................19 Thallium.......................................................................................................... ............................... 20 Arsenic.............................................................................................................. .............................21 Antimony........................................................................................................... .............................21 InhaledUltrafine Silica .................................................................................... ............................... 23 Selenium.......................................................................................................... ............................... 24 AirQuality ............................................................................................................. .............................25 Particulates(PM 2.5) ......................................................................................... .............................25 94 That the operation will constitute a direct and substantial physical hazard to public health and safety or to a neighboring dwelling house, school, church, hospital, commercial or industrial building, public road or other public property, excluding matters relating to use of a public road; ...................... 26 Environmental Justice Violations ........................................................................ ............................... 26 Threats.................................................................................................................. ............................... 28 Hydrogeology.................................................................................................. ............................... 28 DiabaseDikes ................................................................................................... .............................28 46 That previous experience with similar operations indicates a substantial possibility that the operation will result in substantial deposits of sediment in stream beds or lakes, landslides, or acid waterpollution; ........................................................................................................ ............................... 30 1 97 That the applicant or any parent, subsidiary, or other affiliate of the applicant or parent has not been in substantial compliance with this Article, rules adopted under this Article, or other laws or rules of this State for the protection of the environment or has not corrected all violations that the applicant or any parent, subsidiary, or other affiliate of the applicant or parent may have committed under this Article or rules adopted under this Article and that resulted in: ............................................................. 30 DukePenalties and Fines ..................................................................................... ............................... 30 Additional Reasons for the Denial of all Permits .................................................... ............................... 32 BADFAITH ........................................................................................................ ............................... 32 Recommendationsand Solutions ............................................................................... .............................33 1. Deny Permits for Plastic Liners — Plastic HDPE liners are a cheap short term solution ............. 33 2. Deny Permits for Long Distance Transport — Transporting coal ash is a form of Environmental Injustice, and it introduces coal ash toxins into the air, roadways, and railways all across the state. 33 3. Grant Duke a Permit for Solidification of Coal Ash —On site and on Duke Energy Property... 33 Bibliography............................................................................................................ ............................... 34 2 #2 That the operation will have unduly adverse effects on potable groundwater supplies, wildlife, or fresh water, estuarine, or marine fisheries; HDPE Liners for Coal Ash Dumps HDPEliners in landfills and other applications fail or are made to fail as follows: • Inadequate welding and attachment to structures • Imposed stresses during construction • Mechanical damage during construction • Stress cracking at stress points • Sarvice stresses that separate welds Tearing and Punctures 0 Base liner installation and subgrade preparation at Airport ➢ Given that dump trucks and bulldozers will be driving over the thin liner plastic, and given historical records that show that stress and damage during construction is the major cause for leakage in the first years of use, Duke /Charah's permits should be denied. They have neither proposed a means of protecting the liner, nor laid out a specific plan for how to detect and fix leaks and punctures in the HDPE liners. Peggs ID. Geomembrane Liner Durability: Contributing Factors and the Status Quo. Ecotoxicol Environ Saf. 2009;72(3):838 -842. Reddy, D. & Butul, B. A comprehensive literature review of liner failures and longevity. Florida Cent. Solid Hazard. Waste Manage. (1999). at <http: / /epa.gov /region05/ cleanup / rcra/ ClintonLandfill/ PDFClintonLFChemicalWaste _USEPAApplication /c 1_044.pdf> Cracking Fig. 7. Cracking took place at the edge of fillet extrusion seam. Fig. 8. Cracking within and at the edge of a filet extrusion seam. • "Except for poor welding and damage induced during installation HDPEgeomembranes have generally only failed by stresscracking (a fundamental performance characteristic of HDPE) or as a combination of oxidation followed by stress cracking (SC)" "Geomembrane liners are ideally designed to be installed without stress. They are simply intended to act as a barrier... Clearly, a zero stress installation is practically impossible to achieve — wrinkles are unavoidable." ➢ Impermeability "It must be recognized that nothing is absolutely impermeable." ➢ Actually, even HDPEpharmaceutical medicine bottles when completely heat sealed still allow water vapor to pass through. Chen Y, Li Y. Determination of water vapor transmission rate (WVTR) of HDPE bottles for pharmaceutical products. Int JPharm. 2008;358(1- 2):137 -143. ➢ "However, such diffusion `leakage' pales into insignificance compared to stone punctures and bulldozer blade rips" In pract ice aconfined HDPE geomem brane wi I I usually fail in the long term eit her by st ress cracki ng at pointsof constant stress: • stone protrusions, • stresses across seams, • creased w r i n kl es, • t ext u red su rf aces. Reddy, D. & Butul, B. A comprehensive literature review of liner failures and longevity. Florida Cent. Solid Hazard. Waste Manage. (1999). at <http: / /epa.gov /region05/ cleanup / rcra/ ClintonLandfill /PDFClintonLFChemic alWaste_USEPAApplication /c 1_044.pdf5 F1 "Stressed areas have also been seen at temporary dividing berms where the vertical pressure of waste has caused the berm to spread laterally on the continuous liner - there may be wrinkling on one side of the berm and significant tension on the other side." "However, a landfill in Minnesota had a bulldozer nick near a sump during construction that was repaired. The system, with waste on the floor, operated without any leak indication for about three months. Leakage then started at a rate of about 5000 1pd. equivalent to a hole of about 6 mm diameter under a 300 mm hydraulic head" Statistics of Liner Damage from Actual HDPElined landfills Table 3: Statistics of Uner Damage WHENIWHERE AMOUNT DETAILS AMOUNT Linerinstollotion 24' Exirvslon 61% Melting 18% Stone Puncture 17% Cuts 4% Covering 73% Stone Punctures 687D Heavy Equipment 16% Grade Stakes 16% Post - Construction lib Heavy Equipment 679b Construction 31% weather. etc. 2% Hal Floor 78% Stones 819b Heavy Equipment 13% Corner. Edge 9% Stones 59% Heavy Equipment 195 Welds 18% Under Pipes 4% Stones 30% Welds 27% Heavy Equipment 14% Worker 15% Cuts 14% Pipe Penetrations 2% Welds 91% Worker 8% Cuts 1% Road, Storage, etc. ' ¢ Heavy Equipment 437D Stones 21% Worker 19% Welds ' 7 ➢ Given all these sources of leaks and punctures, what plan does Charah have to eliminate these? Peggs ID. Geomembrane Liner Durability: Contributing Factors and the Status Quo. Ecotoxicol Environ Saf. 2009;72(3):838 -842. Reddy, D. & Butul, B. A comprehensive literature review of liner failures and longevity. Florida Cent. Solid Hazard. Waste Manage. (1999). at <http: / /epa.gov /region05/ cleanup/ rcra/ ClintonLandfill /PDFClintonLFChemicalWaste USEPAApplication /c 1_044.pdf5 Studies of landfill leachate chemistry and degradation processes suggest that landfills managed using typical current approaches will take hundreds, if not thousands, of years to stabilize (Hall et al 2003). It is only after this period that they will no longer pose a pollution hazard to their surrounding environment. "Once a liner is covered by several meters of waste the agents for the future development of holes in the liner are limited. The evidence to date from ELL surveys and monitoring of leakage detection layers shows that holes are unlikely to develop for at least the first decade of the service life of the geomembrane liner, and probably significantly longer." ➢ In other wordsy if all the common installation sources of holes and punctures are totally avoided, then studies show you may have at least 10 years of intact liners. "However, to further complicate matters, the exact combinations of circumstances that generate stress cracking are also not well established. In o pulp mill black liquor pond (effectively a confined situation) at an incoming liquor temperature of about 70 °C environmental stress cracking (due to detergent in the liquor) occurred at the tops of wrinkles in an indiscriminate fashion small wrinkles on The floor were cracked but large kinked wrinkles at the toes of slopes were not. Intermediate wrinkles on the slopes also cracked indiscriminately. Therefore, it is impossible to predict the combinations of parameters that will generate environmental stress cracking." ':' Needham AD, Smith J WN, Gallagher EMG. The service life of polyethylene geomembrane barriers. Eng Geol. 2006;85(1- 2):82 -90. doi :10.1016 /j.enggeo.2005.09.030. 31 Microbial Breakdown "The ability of microorganisms to use polyethylene as a carbon source has only been recently established. This result has significance both from an environmental point of view, due to the accumulation of millions of tons of waste plastics every year, but also regarding the conservation of integrity for infrastructures incorporating this plastic. A number of microorganisms with the ability to grow on polyethylene have been isolated. The effects of these microorganisms on the physiochemical properties of this polymer have been described; these include changes in crystallinity, molecular weight, topography of samples and the functional groups found on the surface. Although the bio- degradation and biodeterioration of polyethylene has been demonstrated by several researchers, the enzymes involved and mechanisms associated with these phenomena are still unclear. Research performed in polyethylene biodegradation, both using pure strains as well as complex microbial communities has proved that biodegradation of this material although slow is actually happening in nature. The richness of microorganisms able to degrade polyethylene is so far limited to 17 genera of bacteria and 9 genera of fungi. Polyethylene is a hydrophobic, high molecular weight molecule, and therefore it is commonly accepted that biofilm colonization is the initial step for degradation of this polymer (Gilan et al., 2004) Complex biofilm communities comprised of different microorganisms have been detected on polyethylene surfaces once they were exposed to different biotic environments (Albertsson et al., 1995; Orhan and Biiyiikgiing6r, 2000; Yamada - Onodera et al., 2001; Shimada et al., 2002; Gilan et al., 2004; Hadad et al., 2005; Sivan et al., 2006; Chiellini et al.,2007; Sudhakar et al., 2007; Satlewal et al., 2008; Koutny et al.) ➢ In summary, in 2014 the ability of microorganisms to feed on HDPE liners has just been established and is not well understood yet. Any claim by Charah about the duration of the liners is based on very incomplete knowledge of liner breakdown by bacteria and fungi. Restrepo- Fl6rez JM, Bassi A, Thompson MR. Microbial degradation and deterioration of polyethylene - A review. hit Biodeterior Biodegrad. 2014;88:83 -90. doi :10.1016 /j.ibiod.2013.12.014. 11 pH Controls 4.2. Mobility of elements • "Element concentrations in leachates were greater when water was the leachant (SCLP) than when the acetic acid solution was the leachant (TCLP) for the oxyanion - forming elements As, Mo, Se. U. and V. The opposite was the case for most other elements, including Cd, Co. Cu. Ge, Mn, Ni, TI, and Zn. In general, transition metals will be sorbed at high pH due to negatively charged surface sites; more sorption of oxyanions will occur at low pH due to positively charged surface sites. " "The behavior of trace elements in ash over varying pH is complex, however: • some elements have been observed to leach more from CCP5 as pH increases, • some leach more as pH decreases. • and some amphoteric or oxyanion- forming elements leach more in both acidic and alkaline environments than in neutral ones (Dellantonio et al.. 2010: Kosson et al.. 2009: Zandi and Russell. 2007), " "This complex behavior makes it difficult to assess the modes of occurrence of trace elements in CCP5 using only SGLP and TCLP. as these two leaching procedures provide only two pH- points to characterize potentially" ➢ According to the findings above, the leaching of toxic metals is dependent on the pH. Does Charah have any specific plans for how to handle the varying toxic components as the pH of the ash changes over time? 1. Jones KB, Ruppert LF, Swanson SM. Leaching of elements from bottom ash, economizer fly ash, and fly ash from two coal -fired power plants. Int J Coal Geol. 2012;94(June 2010):337 -348. N. Gulf Creek Wetlands Area roughly inside the blue oval is the Gulf Creek wetlands between Corinth Rd and the Cape Fear River. This extensive area of braided creeks, cattails, bullrushes, marsh, and beaver lodges and dams supports a wide range of water fowl and wildlife. If toxins from the tributary running through Brickhaven drains sediment, heavy metals, and other toxins into this wetland, a valuable Chatham County wildlife area will be lost Hydric Soils and Floodpla Southeast Chatham County Clay Pir I� Hytlric Soils f'� tMyr. Fbotlplain Flood plain and hydric soil maps provided by .bhn Anagnost, Jani FRadhakrishnan, and Brad 9ierman 9 I� r i f lr; WaYw I ,I rbmna ryw U a^� M +m camp +^ Chatham Wetlands and Floodplain — 0 Southeast Chatham County. NC Flood plain and hydric soil maps provided by .bhn Anagnost, Jani FRadhakrishnan, and Brad 9ierman 9 I� Gulf Creek Wetland photographs — These illustrate the varied habitats and wide expanse of wetlands that are threatened by toxic runoff and toxic leachates from the proposed Brickhaven coal ash site. The Colon Road site has extensive creeks and ponds which are not shown here. Wood duck nest and cattails 4/4/2015 9:33am Lat:35 33V'30.7" N Lon: 79 1V'43.5" W , Beaver Lodge 4/4/2015 8:23am Lat: 35 33` \49.3 Lon: 79 1V'32.9" W 10 11 Wildlife Northern Long Eared Bat Scientific Name Myotis septentrionalis Classification: Federally Endangered This species was placed on the Federally Endangered Species list in April, 2015. • Section 4.4 of Charah's 2014 "Threatened and Endangered Species Review" states that "Currently there are no regulations protecting this species and no development constraints due to its potential Presence" This needs to be corrected and updated. • Charah's report further states: "Suitable summer habitat for the Northern long — eared bat does exist within the proposed site and permanent removal of forested habitat may adversely affect this species. The timing of tree clearing activities at the site may be affected once the final listing decision is made. Once listed, a moratorium on tree cutting could go into effect from approximately May 15th to August 15th. • The noise, land clearing, excavation, and construction of the Colon Road site add serious threats to the Northern Long Eared Bat. The Northern Long -Eared Bat is probably a resident of the woods in and around the proposed Lee and Chatham dump sites. This species was once found across much of the eastern and north central United States and parts of Canada. Due to a fungal disease, the species "has declined by as much as 99 percent" from the recent population levels. The US Fish and Wildlife range maps for this part of North Carolina are shown below with a close -up of the Chatham and Lee portion of the range. ,in„ o reensboro ��' flockY Mwnl — RnI�ILhI 1 '1.11'1011! '_. °Lr rnelryJl. - Jdf JaI M / )1 �✓ R 4"-1 � wl moon [clap of Species occurrence 3,5 xLanL� z nL can Je.nvry k = -__ show Lavernenu li - e Eye '�� Mu � aY L. Je.Cng La Me seal /`R�GOldsmn ``l (!1 I�'- l�sllawou y/,na„ II �Y H.irn6 3 } �/ Heservorl F[IOIAY- VA�fNA.,yFrings 114 }�� - 1006 Cen�oJn �u 1r' �nriners 1t ales r o loo /(r i10 / / MOOre CO Y � Mist - netting and acoustic data indicate that the northern long -eared bat may be active almost year - round in eastern portions of the State, likely due to mild winter temperatures and insect availability in coastal counties" (North Carolina Department of Transportation 2014, in litt.) 12 Charah, Inc. (C1earWater Environmental Consultants Inc.). Threatened and Endangered Species Review and Habitat Assessment. August 27, 2014:1 -8. hops: / /www.flickr.coM/ photos/ usfwsrnidwest /16581706021/in/set- 72157650499339699 General Information The northern long -eared bat is a medium -sized bat about 3 to 3.7 inches in length but with a wingspan of 9 to 10 inches. As its name suggests, this bat is distinguished by its long ears, particularly as compared to other bats in its genus, Myotis, which are actually bats noted for their small ears (Myotis means mouse- eared)- The northern long -eared bat is found across much of the eastern and north central United States and all Canadian provinces from the Atlantic coast west to the southern Northwest Territories and eastern British Columbia. The species' neap of species occurrence range includes 37 states. White -nose syndrome, a fungal Initial E�tent Zogm In Zoom out I Pa r Identify disease known to affect bats, is currently the predominant r threat to this bat, especially throughout the Northeast where the species has declined by up to 99 percent from on Ciry Greensboro inston -Sal xrn� pre- white -nose syndrome levels at many hibernation sites. o o Rocky M—ni o D�rrham Although the disease has not yet spread throughout the 'r j., ' �' «F Raleigh , northern long -eared bat's entire range (white -nose tGreenville o r=� syndrome is currently found in at least 25 of 37 states Charlotte R R !NA where the northern long -eared bat occurs), it continues to � Mr spread. Experts expect that where it spreads, it will have " Jacksoi the same impact as seen in the Northeast. This species is listed wherever it is found, but Corurti(a -- •,, 13 r Show Layer Menu "rl 0 ,Vira inla Beach Cape Fear Shiner Scientific Name: Notropis mekistocholas Classification: Federally Endangered, State Endangered Photo by Richard G. Biggins, U.S. Fish and Wildlife Service. Habitat Preferences The Cape Fear Shiner, a species that is federally recognized as endangered, faces potentially severe impacts from both the Brickhaven and the Colon Road coal ash dumps. The Cape Fear Shiner is most often found in shallow, rocky shoals within main river channels. In winter months, they may migrate into smaller tributary streams. This species prefers clean substrates composed of gravel, cobble, and boulders. The Cape Fear Shiner isthreatened by "river impoundment, altered stream flows, and degraded water quality of tributaries and main stems are documented sources of impairment to the habitat. KWAK, THOMAS J. Restoration of Cape Fear Shiner Populations in North Carolina: Assessment of Habitat Suitability http:// www4 .ncsu.edu /— tkwak/shiner.html The Cape Fear shiner is an imperiled minnow species endemic (found nowhere else in the world) to the Cape Fear River basin in the North Carolina piedmont. Populations are currently limited by dams restricting movement and degraded water quality impacting survival and health. 14 The Charah "Environmental" impact report states: Suitable habitat for the Cape Fear shiner does not exist within the proposed project boundary. The streams on sitc arc inter ittent and did not have base flow at the time of the delineation_ [t is the opinion ofCEC that the proposed project is not likely to adversely off= the Cape Fear shiner. Charah, Inc. (Clearwater Environmental Consultants Inc.). Threatened and Endangered Species Review and Habitat Assessment.August 27, 2014:1 -8. ➢ They may not occur in the streams by the sites, but they will be impacted by leachate and contaminated runoff into creeksthat drain into the Cape Fear. While the Cape Fear Shiner may not enter the proposed project boundaries, this species probably does enter some of the creeks, such as Gulf Creek or 9haddox Creek that drain directly from those sites. Distribution "Distribution by County: Cape Fear Rver Basin: Chatham Co. (Fbcky Ewer, including Bear Creek; Deep Ewer, and Haw Ewer); Lee Co. (Deep Ewer), Moore Co. (Deep Ewer, including Falls Creek), Randolph Co. (Deep Ewer , including Fork Creek). N" "NOTE All headwater areas that flow into these occupied habitats should receive Special management. " Habitat Preferences The Cape Fear Shiner is most often found in shallow, rocky shoalswithin main river channels. In winter months, they may migrate into smaller tributary streams. The most obvious features of their preferred habitat are large islandsand barsof water willow, Justiciaamericana, or other instream vegetation. ➢ "This species prefers dean substrates composed of gravel, cobble, and boulders" ➢ "As this species and other endemic fish populations become increasingly isolated and rare, their vulnerability to catastrophic even% such aschemical spillsy and to cumulative, subtle degradation of physical habitat and water quality are greatly enhanced." Hewitt AH, Cope WG, Kwak TJ, Augspurger T, Lazaro PR, Shea D. Influence of water quality and associated contaminants on survival and growth of the endangered Cape Fear shiner (Notropis mekistocholas). Environ Toxicol Chem. 2006;25(9):2288 -2298. doi: 10. 1897/05-569R. 1. http: / /www.ncwildlife.org/Le aming/Species /Fish /CapeFearShiner. aspx #2513696- detailed - information W Other threatened wildlife 1140- §30'00 OA§-< Four -toed salamander (Hemidactylium scutatum) State Listing: Species of Special Concern This salamander is quite rare in North Carolina. "They generally live in forests surrounding swamps, bogs, marshes, and temporary bodies of water which are free of fish." The wetlands around both the Lee and Chatham sites should be surveyed for the presence of these. Wilson, J. Four Toed Salamander. Davidson Herpetology. http:// bio.davidson.edu/hefpcons/hefps of NC /salamanders /Hemscu /Hem_scu.html Illustration by Gillian Harris. "Four -toed salamander (Hemidactylium scutatum)." Gale Science in Context. Detroit: Gale, 2004. Science in Context. Web. 3 May 2015. 16 #° :50c , G §... #<° nip Cambarus (Cambarus) davidi Cooper 2000 Common Name: Carolina Ladle Crayfish Classification: Nongame Fish - Crustacean Although this crayfish is not on the state or federal endangered species list, it is endemic to the Cape Fear and Neuse River. Due to the very limited range and small populations, both sites should be surveyed to see if the Carolina Ladle Crayfish is present. National Range: "Apparently limited to the upper Neuse and Cape Fear river basins in the eastern Piedmont Plateau of North Carolina" (Cooper 2000a). NC Physiographic Region(s): eastern upper piedmont River Basin(s): upper Cape Fear, upper Neuse Adult Habitat: streams (under larger rocks) and burrows Range in North Carolina. North Carolina Wildlife Resource Commission. r II http : / /www.ncwildlife.org/Leaming/ Species /Crustaceans /CambarusCdavidi. aspx #43 911185-detailed- information 17 #3 That the operation will violate standards of air quality, surface water quality, or groundwater quality that have been promulgated by the Department; Toxins There are a wide range of heavy metals and other toxins that are found in coal ash. The specific details of the toxins present and the concentrations vary widely due to differences in the source coal, the weathering conditions, and the combustion type — including fly ash and bottom ash. Below, I present a few research findings on a few toxins. Hexavalent chromium, thallium, arsenic, antimony, and selenium have all been found in Duke's coal ash and NC DENR has found high levels of some of these in water wells adjacent to coal ash dumps in North Carolina. Hexavalent Chromium (or Q'(M) ) "Workplace exposure to Cr(VI) may cause the following health effects: • lung cancer in workers who breath the airborne Cr(VI); • irritation or damage to the nose, throat and lungs (respiratory tract) if Cr (VI) is inhaled; and • irritation or damage to the eyes and skin if Cr(VI) contacts these organs. (OSHA 3373) -U.S. Department of Labor. OSHA " Hexavalent Chromium" p.5 2009 . "The employer must inform any person who launders or cleans protective clothing or equipment contaminated with Cr(VI) of the potentially harmful effects of Cr(VI) exposure, and that the clothing and equipment should be laundered or cleaned in a manner that minimizes skin or eye contact with Cr(VI) and prevents exposure to Cr(Vl) in excess of the PEL. Removal of Cr(VI) from protective clothing and equipment by blowing, shaking, or any other means that disperses Cr(VI) into the air or onto a worker's body is prohibited." "These metals can affect human health in a variety of ways... large amounts of any of them can cause poisoning. The toxic effects of heavy metals in the human body can result in • malfunctioning of the mental and central nervous- system function, • low energy levels and • damage to blood composition, lungs, kidneys, liver and other vital organs. • Long -term exposure to some elements has been seen to result in slowly progressing physical, muscular and neurological degenerative processes that have similar symptoms to Alzheimer's disease, Parkinson's disease, muscular dystrophy and multiple sclerosis. • Contact with heavy metals can also exacerbate allergies and long -term contact may even cause cancer. Hester, R E, and Harrison, R M, eds. Issues in Environmental Science and Technology, Volume 27: Electronic Waste Management. Cambridge, GBR: Royal Society of Chemistry, 2008. ProQuest ebrary. Web. 3 May 2015. "Epidemiologic studies of workers in chromium chemical production and use link exposure to lung and nasal cancer." Hayes, R.B. The carcinogenicity of metals in humans. Cancer Causes Control. 1997 May;8(3):371 -85. 19 Thallium Thallium has been found in some of the wells next to Duke's coal ash dumps. Although it is not present in large amounts, it is a serious health risk. Thallium was the primary ingredient in rat poison until the 1970's when it was banned in the US due to the extreme toxicity. Thallium can be absorbed through the skin, and can also be inhaled or ingested. Any amount of thallium in the body shall be considered abnormal (Reed et al., 1963). According to Mulkey and Oehme (1993), thallium levels in normal human and animals are <1 ppb in blood and urine, and <10 ppb in tissues. ..chronic thallium poisoning mimics many other diseases .. but accidental poisoning caused by contact with thallium- containing materials or their careless handling occurs more frequently. Thallium has received much more attention as an environmental pollutant since high thallium contents were found in cement powders discharged from stacks and emissions from brickworks, and that had contaminated adjacent farmland (Liem et al., 1984). Thallium toxicity Sonia Galvan- Arzate, Abel Santamaria • If the possibility exists that Brickhaven and Colon Road — already — may have experienced some high exposures to thallium, then this should be checked both in community members in the surrounding areas, but also in the local soils. Additional exposure to thallium may be unusually serious if levels are already high from the brickworks. Henderson B. Metals found in wells at NC coal plants. Charlotte Observer. January 24, 2012. Diaz S. The Scoop on Coal Ash at Asheville Plant in North. Asheville; 2015. Human and Ecological Risk Assessment of Coal Combustion Wastes. U.S. EPA (Draft).; April, 2010. 20 Arsenic • Early life isatime of heightened vulnerability to arsenic • Arsenic is "a widespread contaminant of groundwater linked (o cancer, cardiovascular disease, and other adverse health effects. CBS News. "Officials: Unsafe Levels of Arsenic from Duke Energy Coal Ash Dump Pouring into River. Feb. 18, 2014. "Occupational and environmental arsenic exposure is linked to increased lung cancer risk in humans" Hayes, R.B. The carcinogenicity of metals in humans. Cancer Causes Control. 1997 May;8(3):371 -85. Henderson B. Metals found in wells at NC coal plants. Charlotte Observer. January 24, 2012. Schmidt CW. News - Science Selections Arsenic Exposure in Infancy. Environ Health Perspective. 2015;123(5):1289. Antimony Antimony is one of the toxins found in wells recently tested near Duke coal ash dumps. "Even Duke got a warning letter from state health officials, because the well supplying the Buck plant tested higher than state groundwater standardsfor antimony, a potentially harmful metal found in coal ash." 1 • "An overview of inorganic antimony and arsenic compounds points out that the effects of arsenic and the chemically related antimony are similar." • "Antimony passes the human placenta after inhalation exposure and was demonstrable in mothers' milk. " • "In humans, exposure over a number of years causes nose bleeds, damage to the nasal septum and antimony pneumoconiosis (dust lung disease)." • "Antimony and its compounds accumulate in the lungs after inhalation exposure. A very slow absorption occurs after oral administration. The presence of antimony can be demonstrated in practically all body tissues after inhalation or ingestion." • "Long -term inhalation of antimony trioxide dust or antimony ore dust (46 % antimony, mainly as antimony trisulfide) caused lung tumors in female rats. There is evidence of an increase in lung cancer mortality in humans." • "Exposure can also occur via contaminated water, food, and soil contact. In 1916, antimony exposure was associated with lead intoxication, with symptoms including headache, abdominal 21 pain, constipation, colic, distaste for food, loss of appetite, small mouth ulcers with salivation, dizziness, loss of weight, albuminuria, and glycosuria ". After inhalation exposure to metallic antimony or antimony trioxide, antimony was demonstrated in humans in mothers' milk and in the fetal liver. 2 Antimony and its inorganic compounds ( inhalable fraction). 2007;23:1 -73. 1. Bergeron J. Duke offers water to families after most recent test results. Salisbury Post. http : / /www.salisburypost.com/2015 /04/28 /duke - offers - water -to- families- after - most - recent - test - results /. Published April 28, 2015. 2. EU (2004) Risk Assessment Report. Diantimony trioxide. Draft of July 2004, Brussels, Belgium 22 Inhaled Ultrafine Silica Crystalline silica has been classified as a human lung carcinogen. Additionally, breathing crystalline silica dust can cause silicosis, which in severe cases can be disabling, or even fatal. The respirable silica dust enters the lungs and causes the formation of scar tissue, thus reducing the lungs' ability to take in oxygen. There is no cure for silicosis. "Crystalline Silica Exposure Health Hazard Information for General Industry Employees" US Department of Labor Occupational Health and Safety Administration OSHA 3176. 2002 (Revised) https: / /www.osha.gov/ Publications/osha3176.htm1 http : / /bismarcktribune.com /bakken/ crime -up- percent -last- year -in- north- dakota/article f0a23ec4 -f940- 11 e2- ad25- 0019bb2963f4.htm1 23 Selenium (U.S EPA. 2009: Table 11). These criteria are the freshwater criteria maximum concentration (CIVIC), to which aquatic life can be exposed briefly without unacceptable effects, and the freshwater criteria continuous concentration (OOC), to which aquatic life can be exposed indefinitely without unacceptable effects. However, some regulators (e.g., US EPA. 1990) have accounted for the dilution and attenuation of contaminant concentrations by using a general DAFoC 100 (i.e.. contaminant concentrations at a site of interest such as a well or a waterway are assumed to be 1 %of those at a nearby contaminant source). No elements in the 9GLP leachates from the 0CP5 from either power plant (Tables 7 and 8) exceed t he CM C5 or 000s (Table 11) after applyi ng a OAF of 100. Wit hout applying this OAF and considering only undiluted, unattenuated leachates. As. Cr, and Se in some 9;I.Pleachatesexceed the CMCand /or OOC, • No CVICexistsfor Se, but S LPRy Ash leachate from the Ohio plant contains about 32 timesas much Se asthe COG SGLPfine fly ash leachate from the New Mexico plant (Table 8) contains Seat up to 66 timesthe COC, and all types of EFA and FASCLPleachate from this plant contain at least 24 times the OOC Belews Lake, North Carolina, was contaminated by selenium in wastewater released from a coal -fired electric generating facility during 1974 -1985. Selenium bioaccumulated in aquatic food chains and caused severe reproductive failure and teratogenic deformities in fish. • Selenium is passed from parents to their offspring in eggs. • A principle component of the selenium paradigm in Belews Lake or any other contaminated body of water is that as long as selenium is bioavailable from sediments, fish and wildlife are at risk. • Because selenium bioaccumulates (gets increasingly concentrated as it moves through the food chain), the risk remains serious " regardless of the concentrations in water or other ecosystem components." • It is clear that the time frame necessary for complete recovery from selenium contamination in freshwater reservoirs can be on the order of decades. 1. Lemly a D. Ecosystem recovery following selenium contamination in a freshwater reservoir. Ecotoxicol Environ Sqf. 1997;36(3):275 -281. doi:10.1006 /eesa.1996.1515. 24 Air Quality Particulates (PM 2.5) "It is well- established that atmospheric particulate matter (PM) is responsible for a variety of adverse health effects on humans. Atmospheric PM, most notably particles <25 pm in aerodynamic diameter(PM2.5), have been correlated with both acute and chronic adverse health effects (Dockery and Pope, 1994). " "Among other conditions, PM has been correlated with lung inflammation (Farina et al, 2011; Halatek et al., 2011; Lin et al, 2011), exacerbation of asthma (Kelly and Fussell, 2011: Spira- Cohen et al., 2011; Tzivian, 2011), increased hospital visits, cardiovascular problems (Terzano et al., 2010), and increased mortality (Dockery et al, 1993; Guaita et al, 2011)." 25 #4 That the operation will constitute a direct and substantial physical hazard to public health and safety or to a neighboring dwelling house, school, church, hospital, commercial or industrial building, public road or other public property, excluding matters relating to use of a public road; Environmental Justice Violations Colon Road: 3 Mile Map by Don Kovasckitz (2015) Precedents: T.ble _ b -r S � tl3414_31105_M90. a O UJtl14. crpl O e ❑ x�1a n!.bnb.>Jo O- n O tlJa14Jn� I;�..,..n.. ■ ®tlp114j7105fa.m - � tlJW4 us wort. CI�o1.1� IF- 1 p. -11 Cenws 03ock ■l3 -le ■Y lE5 ;; ®tlplla_�n_.m�ty 0 African American Population Centers Lee Co. Map by Dr. John Barnett (2015) • In 1978 North Carolina had 60,000 tonsof soil contaminated with PCB. The state government selected Warren County - a rural site in one of the poorest heavily African American neighborhoods to make a toxic landfill. Then in 2008 the TVA had a massive coal ash spill that spread over 1,000,000,000 gallonsof coal ash slurry across over 300 acres of homes and land and contaminated 2 rivers. The TVA "solved" that problem by digging it up and moving it to a toxic dump in Perry County, Alabama -a predominantly African American county, and one with one of the highest levels of poverty in the United Gates. Now, Duke Energy hasthe Dan Ewer coal ash spill and leaking and unstable coal ash pilesat sites around North Carolina. It wants to perpetuate the history of moving toxic material from one community and dumping on another. This time Duke wants to start this "solution" by moving coal ash from Wilmington and Charlotte to Lee and Chatham County. The selected rural counties and an area that has large African American population. This kind of Environmental Injustice and Environmental Racism needs to stop. The Lee County site is not empty. The map above on the left show a black dot for every household within a 3 mile radius of the Colon Read dump site. The map on the right showsthe racial demographicsof the County. The deep red areasare onesthat have a significant African American population based on the US Census data. The Colon Read site is one of three areas in 26 the county with a large African American group. History is repeating this kind of Environmental Problem Solving It istime for thisto stop. 27 Threats Hydrogeology Not enough is known about the basicswith Triassic Basin groundwater patterns: "No groundwater monitoring stations have been constructed in the Triassic Basins of North Carolina. Because of this, our understanding of the hydrogeology of the Triassic Basins is limited to information that can be recovered from water supply wells, which typically only extend a few hundred feet deep." p. 113 There is insufficient information about the effects of the Triassic Basin faults on the flow of groundwater: ".. the dominant fault orientations in the Triassic basins of North Carolina are northwest - southeast and, to a lesser extent, northeast - southwest. The degree to which these faults may transmit water is not well understood and warrants additional investigation." p. 113 North Carolina Oil and Gas Study under Session Law 2011 — 276. NCDENRand NC Dept. of Commerce. ,April, 2012 "Hydraulic characteristics of the diabase dikesvaried greatly, and appear to be a function of dike thickness and the relative location within the dike and surrounding contact zone... However, the lessweathered diabase tendsto be very highly fractured, resulting in a zone of very high hydraulic conductivity. Diabase Dikes Existing and induced fractures in North Carolina's shallow shale are significant and cannot safely be ignored. These may provide a direct conduit from surface coal ash contamination into groundwater. "Fractures in rocks are recognized as the predominant pathways of resources and hazardous materials, such as groundwater, hydrocarbons, geothermal fluids, and the high - level nuclear wastes, because fractures usually have much greater permeability than the matrix permeability." Ishibashi, T., N. et al. GeoFlow: A novel model simulator for prediction of the 3 -D channeling flow in a rock fracture network, Water Resource. Res., 48, 2012. SiBssi on Law 2011 -276" April, 2012. Diabase dikes are very common in Lee County and most of the Triassic Basin. Dense dusters of dikes like this are known as a "swarm of dikes ". Sanford Sub- Basin. NCGeol. aArvey (2010) Peid, Taylor, Cumberbatch Diabase Dikesof Eastern Redmont of NC(1978) Burt, Carpenter, McDaniel, Wilson Diabase dikes are probably far more common that is shown on the maps: "Larry Daw, a Licensed Geologist in the State of North Carolina, carried out a lot of the geological field work during the Low Level Radioactive Waste Study. The site was in a very similar area in the Triassic Basin next to Sharron Harris. He found: "The diabase dikes at that site were far more common that what was shown on the geological maps of the area" - Personal communication, June 2013. Dikes are known to serve as conduits for the flow of water: "While diabase intrusions are not particularly permeable features, contact metamorphism of the host rock could provide conduits for groundwater due to stress fractures and joints and high - temperature recrystallization of the rock matrix." "Delineation of mafic intrusions near Bedford (Virginia, USA) using geological and geophysical methods" Keane, James and Gilstrap, Tatiana. Environ Earth Science 66:1393 -1402 (2012) "The intrusion of the diabase dikes and sills at temperatures of 1,200 degrees Fahrenheit baked the country rock, which significantly reduced the country rock's permeability. As the diabase cooled, cracks formed inside the dikes and sills, which provided avenues for water to further weather the diabase. This process provides the potential for a tabular body of groundwater to be held by the country rock like a cistern." p. 25 -26. NCDENR Final North Carolina Oil and Gas Study. April, 2012. "The diabase dikes typically are well jointed, but are too thin to be considered awater- bearing unit. However, the presence of the dikes increases probability for differential weathering, which could enhance ground- water movement along the contact of the dike with the adjacent country rock." In the M EC meeting on September 5t", Ken Taylor was asked about deep di kes as conduits. He said there is no data to show that the dikes do serve as conduits below 400 ft. 29 „ Sanford Sub- Basin. NCGeol. aArvey (2010) Peid, Taylor, Cumberbatch Diabase Dikesof Eastern Redmont of NC(1978) Burt, Carpenter, McDaniel, Wilson Diabase dikes are probably far more common that is shown on the maps: "Larry Daw, a Licensed Geologist in the State of North Carolina, carried out a lot of the geological field work during the Low Level Radioactive Waste Study. The site was in a very similar area in the Triassic Basin next to Sharron Harris. He found: "The diabase dikes at that site were far more common that what was shown on the geological maps of the area" - Personal communication, June 2013. Dikes are known to serve as conduits for the flow of water: "While diabase intrusions are not particularly permeable features, contact metamorphism of the host rock could provide conduits for groundwater due to stress fractures and joints and high - temperature recrystallization of the rock matrix." "Delineation of mafic intrusions near Bedford (Virginia, USA) using geological and geophysical methods" Keane, James and Gilstrap, Tatiana. Environ Earth Science 66:1393 -1402 (2012) "The intrusion of the diabase dikes and sills at temperatures of 1,200 degrees Fahrenheit baked the country rock, which significantly reduced the country rock's permeability. As the diabase cooled, cracks formed inside the dikes and sills, which provided avenues for water to further weather the diabase. This process provides the potential for a tabular body of groundwater to be held by the country rock like a cistern." p. 25 -26. NCDENR Final North Carolina Oil and Gas Study. April, 2012. "The diabase dikes typically are well jointed, but are too thin to be considered awater- bearing unit. However, the presence of the dikes increases probability for differential weathering, which could enhance ground- water movement along the contact of the dike with the adjacent country rock." In the M EC meeting on September 5t", Ken Taylor was asked about deep di kes as conduits. He said there is no data to show that the dikes do serve as conduits below 400 ft. 29 If coal ash leachate seeps out of the plastic liners, or if surface contamination occurs due to spills, windblown ash deposition, or trucking accidents, these would all be in the top hundred feet of soil and rocks. Therefore NC State Geologist Ken Taylor's comment indicates that Lee and Chatham's diabase dike swarm may represent a serious threat to groundwater. #6 That previous experience with similar operations indicates a substantial possibility that the operation will result in substantial deposits of sediment in stream beds or lakes, landslides, or acid water pollution; Duke Energy has dumped a "substantial" amount of coal ash into the Dan River in February, 2014. This was not a simple accident, but was the result of cutting costs by not inspecting and maintaining the ash drainage pipes. #7 That the applicant or any parent, subsidiary, or other affiliate of the applicant or parent has not been in substantial compliance with this Article, rules adopted under this Article, or other laws or rules of this State for the protection of the environment or has not corrected all violations that the applicant or any parent, subsidiary, or other affiliate of the applicant or parent may have committed under this Article or rules adopted under this Article and that resulted in: a. Revocation of a permit, b. Forfeiture of part or all of a bond or other security, c. Conviction of a misdemeanor under G.S. 74 -64, d. Any other court order issued under G.S. 74 -64, or e. Final assessment of a civil penalty under G.S. 74 -64. Duke Penalties and Fines Another example of Duke Energy's lack of concern for human health and active disregard for North Carolina's water happened in March, 2014. At the existing coal ash pits next to the Cape Fear power plant, Duke was caught pumping toxic leachate directly into the canal that runs into the Cape Fear River. Coal ash leachate like this contains heavy metals and other toxins that endanger not only the Cape Fear Shiner, all wildlife downstream of this site, but also all municipal water intakes that are down -river from this site — all the way to Wilmington. For Duke to engage in this type of willful disregard for North Carolina law and endanger human health indicates that the permits they are currently applying for should be denied. This week, Duke Energy plead Guilty to breaking numerous sections of the federal Clean Water Act and State Law. They were fined $120 million dollars for polluting multiple rivers with coal ash. 30 March, 2014 photo of Duke Energy pumping untreated, unfiltered toxic water directiv into a waterwav leading into the Cane Fear River. Just paying the fine does not constitute "correcting all violations" as stipulated in #7 above. Duke should be denied the Brickhaven and Colon Road coal ash permits. The North Carolina Department of Environment and Natural Resources should withhold further consideration of those permits until the Dan River and other rivers have a comprehensive cleanup of current coal ash toxins, take effective action to halt the seepage and leaking of additional toxins into the rivers, and propose a solution to the issue that is long term — unlike the plastic lined clay pit plans. 31 Additional Reasons for the Denial of all Permits BAD FAITH Duke has not acted responsibly and has hidden problems, failed to act on known problems, and has violated state and federal laws. This is not a company that should be allowed to rush through a permitting procedure for a cheap, short term fix to its problems. "Since 2011, monitoring wells surrounding the pits have exceeded state groundwater standards on 226 readings, including for high amounts of boron, manganese, iron and chromium. Residents living near the plant were not informed of the findings, nor did state regulators require Duke to test for contamination on any neighboring properties. Chromium is of concern because in its most toxic form hexavalent chromium it is a known carcinogen." Carolina N, Carolina N. Dukeville concerns over coal ash: 5 things to know. Associated Press - CnsNews.com. http: / /www.cnsnews.com/news /article /dukeville- concerns - over -coal- ash -5- things -know. Published June 17, 2014. Duke is denying the relationship of the well contamination to the adjacent coal ash pits, and is claiming that the substances are naturally occurring. Due to this behavior by Duke, it is imperative that all wells within a half mile of the outer perimeter of the coal ash dump sites be tested by an independent and certified agency. This baseline data will be essential if Duke is allowed to proceed with plastic -lined storage of coal ash on either of the two sites. "Belews Lake, North Carolina, was contaminated by selenium in wastewater released from a coal -fired electric generating facility during 1974 -1985. Selenium bioaccumulated in aquatic food chains and caused severe reproductive failure and teratogenic deformities in fish (Cumbie and Van Horn, 1978; Lemly, 1985a, 1993c). Beginning in 1986, the electric utility company changed its coal ash disposal practices and selenium laden wastewater no longer entered the lake. In the decade since, natural ecosystem processes have operated in the reservoir. There has been no remediation or other manipulations to reduce selenium levels. " Lemly a D. Ecosystem recovery following selenium contamination in a freshwater reservoir. Ecotoxicol Environ Saf. 1997;36(3):275 -281. doi:10.1006 /eesa.1996.1515. Peggs ID. Geomembrane Liner Durability: Contributing Factors and the Status Quo. Ecotoxicol Environ Saf. 2009;72(3):838 -842. 32 Recommendations and Solutions 1. Deny Permits for Plastic Liners — Plastic HDPE liners are a cheap short term solution. 2. Deny Permits for Long Distance Transport — Transporting coal ash is a form of Environmental Injustice, and it introduces coal ash toxins into the air, roadways, and railways all across the state. 3. Grant Duke a Permit for Solidification of Coal Ash — On site and on Duke Energy Property. Advantages: The US Department of Energy is building 2 circular saltstone containers in South Carolina. "The Environmental Management (EM) "program at Savannah River Site(SRS) has built two more low -level salt waste disposal units ahead of schedule and under budget. Construction of these circular units vaults built in the past are rectangular started in late 2010 and was targeted for completion in July 2014. • They were completed seven months early and for $8 million less than the anticipated total cost of $76.5 million." • The next generation of units will be much larger, and "will need only nine of the larger units, which will result in substantial cost savings by requiring less space to design and build. • This could provide local jobs. "The construction contract was awarded to BRADY and Associates of Matthews, N.C." New disposal units being built at Saltstone Of ➢ This solution uses a known and proven technology. ➢ It provides a solution without the continual flow of toxic leachate. It eliminates airborne toxic particulates. ➢ AND — it leaves the material above ground where any problems that arise can be seen and corrected, and the problem is not hidden away to become a future superfund site. 33 Bibliography (National Institute of Health). Selenium Dietary Supplement Fact Sheet. NIH Fact Sheet at <http: / /ods. od.nih.gov /factsheets/ Selenium- HealthProfessional /gh8> 2. Agency, U. E. P. Public Hearing on EPA's Proposed Rule on Hazardous and Solid Waste Management System. (2010). 3. Assessments, H. et al. Table X . Site locations , habitat assessments , land use, and physical - chemical measurements for two Dan River benthic macroinvertebrate sites in Rockingham County, NC, October 28, 2014. 45g = Triassic Basin 2006 NLCD http: / /water.usgs.gov /osw /stre. (2014). 4. Axtell, N. Full text Sierra Club: Duke coal plant violating SO2 health standard. Times News (2015). 5. Bergeron, J. Duke offers water to families after most recent test results. Salisbury Post (2015). at <http://www.salisburypost.com/ 2015 /04/28/ duke - offers - water -to- families- after - most - recent- test- results /> 6. Beyersmann, D. & Hartwig, A. Carcinogenic metal compounds: Recent insight into molecular and cellular mechanisms. Arch. Toxicol. 82, 493 -512 (2008). 7. Blanchard, F. The Life History of the Four -Toed Salamander. Am. Nat. 650,262-268 (1923). 8. Brachman, R. W., Moore, I. D. & Rowe, R. K. Local strain on a leachate collection pipe. Can. J Civ. Eng. 27,1273-1285 (2000). 9. Chen, Y. & Li, Y. Determination of water vapor transmission rate (WVTR) of HDPE bottles for pharmaceutical products. Int. J. Pharm. 358, 137 -143 (2008). 10. Concerned Health professionals of New York. Compendium of scientific, medical, and media findings demonstrating risks and harms of fracking (unconventional gas and oil extraction) 2nd Edition. Physicians Scientists & Engineers for Health Energy at <http://www.psehealthyenergy.org/site/view/I 180> 11. Crumpton, J. Duke Energy's Coal Ash Disposal Plans for Lee County. Jan 29, (2015). 12. Diaz, S. The Scoop on Coal Ash at Asheville Plant in North. (2015). 13. Evans, Lisa; Becher; Michael; Lee, B. State of Failure - How States Fail to Protect Our Health and Drinking Water From Toxic Coal Ash. (2011). 14. Ewers, U. in The Science of the Total Environment 71, 285 -292 (Elsevier Science Publishers, 1988). 34 15. Forschungsgemeinschaft, D. Antimony and its inorganic compounds ( inhalable fraction ). 2, (2006). 16. Fretwel, S. SC Contamination. The Columbia Herald 1 -4 (2015). 17. Giglio, M. G. A Guide to. 1 -51 (2009). doi: St John's 224.2 18. Henderson, B. Metals found in wells at NC coal plants. Charlotte Observer (2012). 19. Holmes, a. L., Wise, S. S. & Wise, J. P. Carcinogenicity of hexavalent chromium. Indian J. Med. Res. 128,353-372 (2008). 20. House, N. C. & Charles, R. Robeson County Employers. 5573 at <http: / /accessnc.commerce. state. nc. us /docs /topEmployers /topEmp_3715 5 .pdf> 21. Hsuan, G. G. Data base of field incidents used to establish HDPE geomembrane stress crack resistance specifications. Geotext. Geomembranes 18, 1 -22 (2000). 22. Jones, K. B., Ruppert, L. F. & Swanson, S. M. Leaching of elements from bottom ash, economizer fly ash, and fly ash from two coal -fired power plants. Int. J. Coal Geol. 94, 337 -348 (2012). 23. Krishnaswamy, R. K. Analysis of ductile and brittle failures from creep rupture testing of high - density polyethylene (HDPE) pipes. Polymer (Guildfl. 46, 11664 -11672 (2005). 24. Langard, S. One hundred years of chromium and cancer: a review of epidemiological evidence and selected case reports. Am. J Ind. Med. 17, 189 -215 (1990). 25. Lemly, a D. Ecosystem recovery following selenium contamination in a freshwater reservoir. Ecotoxicol. Environ. Saf. 36,275-281 (1997). 26. Lemly, A. D. Technical and Scientific Issues with Coal Ash Structural Fills in North Carolina. 27. Lemly, A. D. & Skorupa, J. P. Wildlife and the coal waste policy debate: Proposed rules for coal waste disposal ignore lessons from 45 years of wildlife poisoning. Environ. Sci. Technol. 46, 8595-8600(2012). 28. Lockwood, A. & Fana, F. Ash in Lungs - How Breathing Coal Ash is Hazardous to your Health. 29. Muraswski, J. Lifespan of Duke Energy's coal ash liners debated. News and Observer (2015). 30. Murawski, J. Coal Ash Rarely used as Structural Fill in Triangle. News and Observer 1 -2 (2015). 31. Needham, A. D., Smith, J. W. N. & Gallagher, E. M. G. The service life of polyethylene geomembrane barriers. Eng. Geol. 85, 82 -90 (2006). 32. North, T., Coal, C. & Management, A. Structural Fills at Clay Mines. mi 33. Oehmig, W. N., Roessler, J. G., Zhang, J. & Townsend, T. G. Effect of ferrous metal presence on lead leaching in municipal waste incineration bottom ashes. J. Hazard. Mater. 283, 500 -506 (2015). 34. OSHA. Fact Sheet Health Effects of Hexavalent Chromium Hexavalent chromium is a toxic form of the element chromium. Hexavalent. 35. Peggs, L D. Geomembrane Liner Durability: Contributing Factors and the Status Quo. (2003). 36. Porter, J. THE CANARY IN THE COAL ASH. Indy Weekly 7 -8 (2014). 37. Press, A. Reports: Duke Energy was warned about pipe that caused ash spill. Tampa Bay Times 2015 (2015). 38. Reddy, D. & Butul, B. A comprehensive literature review of liner failures and longevity. Florida Cent. Solid Hazard. Waste Manag. (1999). at <http: / /epa.gov /region05/ cleanup / rcra/ ClintonLandfill /PDFClintonLFChemicalW aste_USEPAA pplication /c1- 044.pdf5 39. Restrepo- F16rez, J. M., Bassi, A. & Thompson, M. R. Microbial degradation and deterioration of polyethylene - A review. Int. Biodeterior. Biodegrad. 88, 83 -90 (2014). 40. Rivin, G. Coal Waste May Cause Carcinogrn Spikes in Drinking Water. North Carolina Health News 41. Rowe, R. K. & Booker, J. R. Modelling impacts due to multiple landfill cells and clogging of leachate collection systems. Can. Geotech. J 35, 1 -14 (1998). 42. Rowe, R. K. & Nadarajah, P. Estimating leachate drawdown due to pumping wells in landfills. Can. Geotech. J. 33,1-10 (1996). 43. Rowe, R., Armstrong, M., and Cullimore, D. Particles Size and Clogging of Granular Material by leachate.pdf. J. Geotech. Geoenvironmental Eng. 129, 775 -786 (2000). 44. Rowe, R. & Yu, Y. Factors affecting the clogging of leachate collection systems in MSW landfills. Proc. 6th Int. Congr. Environ. Geotech. (2010). at < http: / /www.geoeng.ca/directory/kerry pub /2010 6ICEG Rowe and Yu Leachate Collection Systems.pdf5 45. Sager, M. Determination of arsenic, cadmium, mercury, stibium, thallium and zinc in coal and coal fly -ash. Fuel 72, 1327 -1330 (1993). 46. Schmidt, C. W. News I Science Selections Arsenic Exposure in Infancy. Environ. Health Perspect. 123, 1289 (2015). 36 47. Simpkins, D. L., Petherick, G. L. & Dickens, R. S. SECOND PHASE INVESTIGATIONS OF LATE ABORIGINAL SETTLEMENT SYSTEMS IN THE ENO, HAW, AND DAN RIVER DRAINAGES, NORTH CAROLINA. (1986). at <www.rla.unc.edu /Publications /pdf /ResRep6.pdf> 48. Stessel, R. L & Hodge, J. S. Chemical resistance testing of geomembrane. J Hazard. Mater. 42, 265-287(1995). 49. Sullivan, J. EPA Coal Ash Proposal - What is coal? Journal of the Franklin Institute 200, (1925). 50. Thompson, D.; Argent, B. B. Coal Ash Composition as a function of feedstock composition. Fuel 78, 539 -548 (1999). 51. Us Epa, O. Coal Ash. (2000). at <http: / /www.epa.gov/ radiation /tenonn /coalandcoalash.html> 52. Video, L., Service, W., Agency, U. S. E. P. & Resources, N. Environmental Factor, April 2014 UNC Superfund scientists study effects of Dan River coal ash spill. (2014). 53. Wagner, J. A. Dan River Macroinvertebrate Collection Sites ( orange dots). (2014). 54. Xie, S. -H. et al. DNA damage and oxidative stress in human liver cell L -02 caused by surface water extracts during drinking water treatment in a waterworks in China. Environ. Mol. Mutagen. 51,229-235 (2010). 55. Zierold, K. M. Threatened and Endangered Species Review and Habitat Assessment. 1 -8 56. Zierold, K. M. & Sears, C. G. Community Views About the Health and Exposure of Children Living Near a Coal Ash Storage Site. J Community Health 40, 357 -363 (2014). 57. Title: Toxins leaking from 2nd pipe at coal ash dump Source: Daily Herald (Infotrack Newstand) 4 (2014). 58. Hexavalent Chromium. Occupational Safety and Health Administration (2009). at <https: / /www. osha.gov /Publications /OSHA -3 3 73 - hexavalent- chromium.pdf> 59. Cape Fear Shiner. U.S. Fish and Wildlife Service (2005). 60. Discussing Coal Ash Removal at the former Weatherspoon Plant on the Lumber River. 1 (2015). 61. 2014 Coal Combustion Products Study as required by the Coal Ash Management Act. Session La, 62. Data from App. Voices on Chemical Levels. 63. NIOSH Pocket Guide to Chemical Hazards. (2015). at <http: / /www.cdc.gov /nosh /npg /npgd0550.html> 37 64. Human and Ecological Risk Assessment of Coal Combustion Wastes (Draft). (2010). 65. EM Completes Salt Waste Disposal Units $ 8 Million under Budget at Savannah River Site. 66. CFM Protocol + Data Sheet - Google Docs. 67. The Coal Ash Problem. (2015). 68. Criteria For Mining Permit Reviw. (2015).