2016.4.18 Yadkin Riverkeeper Buck Steam Station CAMA Prioritization Comments

April 18, 2016
Via Electronic Mail
N.C. Division of Water Resources
Groundwater Protection Section
N.C. Department of Environmental Quality
Attn: Debra Watts
1636 Mail Service Center
Raleigh, NC 27699-1611
buckcomments (ancdenr. gov
Re: Comments on Buck Coal Ash Prioritization
Dear Ms. Watts:
The Yadkin Riverkeeper submits the following comments urging the Department
of Environmental Quality ("DEQ") to designate Duke Energy's Buck coal ash site as a
high priority in light of the serious risks that the Buck facility poses to nearby
groundwater and the Yadkin River. We will not reproduce the thorough technical and
legal analysis by the Southern Environmental Law Center and our experts. Instead, we
speak to the risks the site poses to our members.
For months now, I have been unable to clearly answer our members in the
Dukeville community when they ask why, if Buck was high risk for a majority of the
factors considered by regional staff, DEQ chose to bound it as a low to intermediate site.
Those residents have seen Duke drilling wells in recent months and have asked how a
final determination can be made when Duke has yet to gather data on almost the entire
southern side of the Buck site where many of their properties adjoin the coal ash ponds. l
would put the same question to DEQ.
I write on behalf not only of the Dukeville community members but for our
members throughout the Yadkin watershed and the state who have written to urge DEQ
to rank this as a high priority site. They wrote because Buck site also poses a high risk to
the Yadkin River and High Rock Lake. Nearly 300,000 people rely on drinking water
intakes downstream of the Buck coal ash pits. A natural -flowing stream -which
community members remember playing in before it was dammed -now runs directly
through the largest coal ash basin at Buck.

Seeps at Buck discharge over 70,000 gallons of water per day according to Duke
Energy's own reports, and these reports did not even consider all of the known seeps at
Buck. These seeps are contaminated with high levels of pollutants like chromium, boron,
aluminum, and lead. And Duke Energy's own reports conclude that pollutants such as
vanadium, hexavalent chromium, antimony, and cobalt will continue to discharge into the
Yakin River for the foreseeable future if the ash is capped in place. Finally, Duke Energy
has a long history of mistakes and spills at Buck, and cannot be trusted to properly
manage the ash in the leaking, unlined pits for eternity.
As the Yadkin Riverkeeper I have personally witnessed the groundwater seepage
flowing from the Buck site into the Yadkin. In November of 2014, Yadkin Riverkeeper
and Waterkeeper Alliance members took samples along the Yadkin riverbank from
nearly a quarter mile of orange, crusted, metallic seeps. Our members include lakeside
property owners, fishermen and hunters who frequent the Yadkin River and High Rock
lake in the vicinity of Buck Steam Station and the ongoing contamination has raised
concerns for people who have boated, hunted and fished this area their entire lives. We
have received numerous questions as to the safety of the fish in Buck and of the
possibility of a dam failure -clear illustrations that the threat Buck represents has a
chilling effect on community members ability to recreate on and enjoy the river and lake.
The dams at Buck are a serious threat to downstream communities. EPA and
DEQ have repeatedly found that the dams at Buck have a high or significant hazard
potential, and that dam failure could close significant economic loss and environmental
damage. Five million tons of ash is stored at Buck, far more than what was stored and
catastrophically released at Dan River. Duke Energy has known about dam safety issues
at Buck—including cracks, leaks, and structures that are "approaching the end of [their]
safe performance life"—for decades. Yet Duke Energy still has not fixed these problems.
DEQ must prioritize Buck as high risk based on the current poor conditions of these
dams, rather than banking on long -overdue repairs.
The public has overwhelmingly voiced their support for designating Buck a high
priority. DEQ must not disregard the public's demands and the dozens of high risk
factors at Buck by dismissing Buck as a low priority.
Regards,
Will Scott
Yadkin Riverkeeper