20150042 Ver 1_George McRae_20150516

Burdette, Jennifer a
From: GEORGE MCRAE <georgefmcrae @gmail.com>
Sent: Saturday, May 16, 2015 5:04 PM
To: SVC_DENR.publiccomments
Subject: DWM,
Attachments: coal ash letter.odt

5/16/2015
Presumably, the purpose of the coal ash project is to reclaim the land. The dictionary defines
reclamation as -" a restoration, as to productivity, usefulness, or morality" This project is a sham since
the land will not be reclaimed; in fact, much of the land to be reclaimed has never been mined but will
be used as a landfill to store toxic material. The question that should be asked is- will this project
protect the environment from the toxic coal ash (a material already contaminating wells in other NC
communities)? I think that the answer is ultimately a resounding -NO! If the project can be
successfully carried out without incident in the short term, the coal ash is inorganic and will not
deteriorate in the dry tomb (reclamation cell) and will therefore remain a potential toxic waste. The
danger to the environment will actually happen in 40 to 50 years or more after the reclamation project
is no longer maintained or monitored. The upper and possibly lower liners will be pierced by
vegetation allowing water to enter the dry tomb. This will result in the build -up of toxic leachate which
will no longer be monitored or removed, and will ultimately result in groundwater contamination.
If the permits are granted, the treatment of the leachate will be a central problem. The leachate will
be an inorganic toxic soup that may be a hazardous waste. Although the coal ash is exempt from being
a hazardous waste, is the leachate exempt? The waste water treatment plants are designed to treat
organic materials. The coal ash leachate will be inorganic and would result in the WWTP sludge being
higher in metals (if not a hazardous waste) and would make disposal more difficult or possibly more
expensive.
The permit applications say that the coal ash has been analyzed using a TCLP test. Since the
analytical technique was designed for hazardous waste and coal ash is expressly exempt under RCRA
legislation, I believe a broader analytical technique should be used as a screening test. Although the
coal ash is presented as a consistent material, I would think that the composition of the coal ash would
be affected by the type and origin of the coal and the type of air pollution device used on the
combustion unit.
I believe that the "reclamation" of land in Lee and Chatham Counties using coal ash is a bad idea
that "kicks the can" down the road. The issuance of permits to allow this project to proceed will result
in a costly mistake, especially in the long -term.
George F. McRae
3400 Deep River Road
Sanford, NC 27330