20070812 Ver 2_Anchor Qea BADIN LAKE DATA REVIEW_20090223

REVIEW OF "BADIN LAKE DATA REVIEW"
DATED: FEBRUARY 2009
PREPARED BY: ANCHOR QEA, LLC
A Report (Review) Prepared for
Stanly County, NC
By
John H. Rodgers, Jr., Ph.D.
102 Santee Trail
Clemson, SC 29631
and
Department of Forestry and Natural Resources
Clemson University
Clemson, SC 29634
February 23, 2009
This purpose of this report is to provide a scientific review of "Kadin Lake Data Review"
(prepared by Anchor QEA, LLC). Prepared for Alcoa Power Generating Inc., the Anchor
QEA document is a meta-analysis that attempts to combine disjunct data sets that were
collected for a variety of disparate purposes. The accumulation of a heterogeneous
mixture of data in this document is used to arrive at some sweeping and important
conclusions that I do not believe can be supported by extant data.
Based on selected sediment and fish data collected to date, this document concludes that
"the sediments near the facility cannot be impacting the lake as a whole or the quality of
water discharged downstream." (p.9) The document goes on to state "that the sediments
near the facility are not a substantive source of PCBs to local fish." (p.9) The
information contained in the Anchor QEA document, the data contained in the cited
reports and the information presented below clearly illustrate that these conclusions and
others contained in the document are neither supportable nor accurate.
1. The Badin Lake Data Review document (the Document) states that it is
intended to review "the existing sediment and fish data for APGI's Badin
Lake." (p.1)
2. The Document notes that the aluminum smelter (Badin Works facility)
operated adjacent to Badin Lake for about 85 years. During that time, the
lake received stormwater runoff as well as permitted (and unpermitted)
industrial discharges from the Badin Works facility. (p. 2) Apparently,
aerial loadings from particulate emissions and other sources were not
considered in this document. This would minimize the importance of
patterns of contaminants around outfalls from the site in terms of
identifying a source.
3. The Document focuses on the PAHs and PCBs in sediments as the main
constituents of concern. While these are certainly constituents of concern,
these are surely not the sole constituents of concern emanating from this
site. (p. 2). Cyanide and other constituents (such as fluoride and
aluminum) associated with smelter operation would be included in a
thorough study, if only as tracers. I believe that it is scientifically
unacceptable to limit the document to PAHs and PCBs.
4. The Document cursorily reviews the sediment data from three Alcoa
studies and one Stanly County study. I have not reviewed the 1996-1997
data from Woodward-Clyde and MFG reports. However, I have provided
specific comments on the RETEC, Environmental Services Inc., and URS
reports previously.
5. The RETEC report (2007) is used to dismiss toxicity in the sediments in
the Lake. I have previously provided comments on the inadequacy of the
RETEC report for that purpose (in my report dated April 29, 2008) and the
nonstandard sampling and analyses.
6. The Environmental Services Inc. report (2008) contained limited sampling
and analyses, but demonstrated the presence of constituents of concern in
sediments in Badin Lake.
7. The URS report (2009) used composited samples and analytical methods
that could not detect PCBs or PAHs at levels of concern, nor could this
study detect patterns related to movement of sediments toward the dam.
In spite of these shortcomings, the URS data demonstrated contamination
of PAHs in sediments at levels potentially posing ecological risks (near
the former smelter site as well as the dam). These data were apparently
overlooked or dismissed in the Anchor QEA Document.
The Document purports to examine PAH and PCB spatial patterns in
Badin Lake Sediment (p. 4). This is puzzling because results from
different sampling devices, handling (compositing vs. discrete) and
analyses are clearly not comparable. For example, Total PAH is
arbitrarily defined in this study as the summed concentrations of the 16
Priority Pollutant PAHs. (p. 4). In a complex and historically
contaminated setting such as this, such an approach for estimating Total
PAHs is likely to grossly underestimate the actual concentrations.
Contrary to the statement (referencing the URS report) that there is a
pattern of decreasing concentration as you move away from the site, the
data for naphthalene and 2-methylnaphthalene do not indicate that this is
the case. Moreover, the data from the URS study cannot be used to
discern any pattern reliably since each transect is represented by only one
composite and one discrete sample.
9. The discussion of the RETEC sample containing 0.76 mg PAH/kg as
background is very troubling. (p.4) If that level is background for the
lake, the entire lake should be considered adversely impacted ecologically
(Buchman 2008). The statement that these data are evidence that there has
been little PAH discharge and that it has not moved from the site is
unsupportable by these data. (p.4-5)
10. As noted in previous reviews of the sediment reports on PCB
concentrations, the analysis of Aroclors underestimates the actual
concentrations of PCBs (Bernhard and Petron 2001; Columbia Analytical
Services 2008). Since analysis of sediments and other matrices for
Aroclors is relatively insensitive (NRS 2001), it is not surprising or
reassuring when PCBs are not detected in these sediments. Reports of
PCB concentrations in sediments of 1 -2.4 mg/kg (p. 5) is certainly of
concern given the inability of the method to detect PCBs.
11. Rather than arbitrarily referring to the sum of 16 Priority Pollutant PAHs
as Total PAH, the Document could have called this aggregation "PAH-
16." PAH-16 refers to the sum total concentration of benz[a]anthracene,
benzo[a]pyrene, benzo[b]fluoranthene, benzo[k]fluoranthene, chrysene,
dibenz[a,h]anthracene, indeno[1,2,3-c,d]pyrene, acenaphthene,
acenaphthylene, anthracene, benzo[g,h,i]perylene, fluoranthene, fluorene,
naphthalene, phenanthrene, and pyrene. These compounds are not
uniform in their toxicity or fate (McIntosh et al. 2004).
12. The Document reviewed fish tissue data for several analytes. This
interesting mix of studies included the statewide fish tissue sampling
(2003-2006) and the recent (2008) sampling for PCBs and PAHs in fish
tissue.
13. I have not reviewed the statewide fish tissue sampling (2003-2006). I
have provided extensive comments on and analysis of the recent fish
tissue study data for PCBs and PAHs (February 2009). As noted in those
comments, the lack of detection of PAHs in fish tissue above quantitation
limits does not mean that there are no risks or concerns. The PAHs
measured are not the only analytes of concern in this situation. The
quantification limits for these data are such that concentrations of PAHs of
concern could be present and they would not be detected. Further, certain
PAHs were specifically identified below quantitation limits (acenaphthene
and fluorene), and others are present but not yet identified.
14. The PCB data from the 2008 study were used by NC DHHS to establish a
fish consumption advisory for Badin Lake. The statement from the
Document that "These levels are in the range of levels typically found at
sites with no known PCB sources (i.e. the levels are consistent with
expected background PCB concentrations)" is unsupported and
unsupportable. (p.7)
15. The statewide study measured 19 of the 209 PCB congeners. Based upon
the recent results, the sum of the results from analysis of less than 10% of
the congeners cannot reliably estimate "Total PCBs" as was done for this
Document. (p. 8).
16. As clearly stated by NC DHHS, the PCB study of fish tissue for Badin
Lake was not intended and insufficient to identify a source or the source(s)
of PCBs. For this Document to contend "that sediments in the SW are not
a source of PCBs beyond that attributable to regional conditions." is not
scientifically reliable and is not supported by the data at hand. (p. 7)
17. The Document points to PCB sources in reservoirs upstream that may be
entering Badin Lake, but is apparently not concerned with the movement
of PCBs from Badin Lake downstream. (p. 7) Indeed, a careful study to
identify the source(s) of PCBs in Badin Lake has not been conducted; nor

has a careful study to discern the transport of PCBs and other constituents
of concern from Badin Lake downstream.
18. The Summary and Conclusions from this Document are without
foundation. We do not have data regarding the source(s) of PCBs in
Badin Lake and we certainly do not have the data to conclude that
"Releases from the Badin Works Facility have had no discernable impact
on sediment PCB concentrations and only a local impact on sediment
PAH concentrations." (p. 9) PCBs and PAHs are important, but they are
not the only contaminants of concern at this site. There is no data or study
to support the contention that "Consequently, the sediments near the
facility cannot be impacting the lake as a whole or the quality of the water
discharged downstream." (p. 9) And most certainly, there is nothing in
this Document to support the final conclusion: "Based on these
observations, continued operation of the Narrows Dam will not adversely
affect water quality downstream of the dam." Although the data in this
Document were marshalled to attempt to support the contention that the
Badin Works Facility was not a source and that downstream areas would
not be impacted, we simply do not have the data or the studies to conclude
this. We have not done the 209 congener analysis for PCBs in the
sediments that have presumably weathered for decades. This Document in
no way alleviates concerns regarding the 401 Water Quality Certification
issues.
Literature Cited and References
Anchor QEA, LLC. 2009. Badin Lake Data Review. Report prepared for Alcoa
Power Generating Inc. 10 pp. + Tables and Figures.
Bernhard, T and S. Petron. 2001. Analysis of PCB congeners vs. Aroclors in
ecological risk assessment. Issue Paper - PCB Congeners in Ecological Risk
Assessment.US Navy.
Buchman, M.F. 2008. NOAA Screening Quick Reference Tables. NOAA OR&R
Report 08=01, Seattle, WA, Office of Response and Restoration Division, National
Oceanographic and Atmospheric Administration. 34 pp.
Columbia Analytical Services. 2008. Testing for PCB Congeners and Aroclors.
Copied from the web site.
McIntosh, A.D., C.F. Moffat, G. Packer and L. Webster. 2004. Polycyclic aromatic
hydrocarbon (PAH) concentration and composition determined in farmed blue
mussels (Mytilus edulis) in a sea loch pre- and post-closure of an aluminum smelter.
J. Environ. Monitoring 6: 209-218.
National Research Council. 2001. A Risk Management Strategy for PCB-
Contaminated Sediments. The National Academies Press. 452 pp.
Rodgers, D.W., M. Dickman and X. Han. 1995. Stories from old reservoirs: Sediment
Hg and Hg methylation in Ontario hydroelectric developments. Water, Air and Soil
Pollution 80: 829-839.
Sebman, E., P.A. Work and E.J. Hayler. 2007. Influence of stratification and
shoreline erosion on reservoir sedimentation patterns. J. of Hydraulic Engineering
133: 255-266.
Suedel, B.C. and J.H. Rodgers, Jr. 1991. Variability of Bottom Sediment
Characteristics of the Continental United States. Water Res. Bull. 27:101-109.
USGS (Gustavsson, B., D.B. Smith and R.C. Severson). 2001. Geochemical
Landscapes of the Conterminous United States - New Map Presentations for 22
Elements. US Department of Interior, US Geological Survey. USGS Professional
Paper 1648.