20070812 Ver 2_Sampling at APGI Projec_20090306

Re: Sampling at APGI Project
Subject: Re: Sampling at APGI Project
From: John Dorney <[e-mail]>
Date: Fri, 06 Mar 2009 14:44:53 -0500
To: "Griffin, III, Thomas N." <[e-mail]>
CC: John H Rodgers <[e-mail]>, Jerry Myers <[e-mail]>, Peter Caldwell
<[e-mail]>, [e-mail], "Ellis, H. Gene" <[e-mail]>, "Bromby, Craig A."
<[e-mail]>, Roger Edwards <[e-mail]>, Jon Risgaard <Jon. Risgaard@ncmai l.net>, John
Dorney <[e-mail]>
Tom - Thank you for your email concerning our sampling plan for water from the discharges. DWQ staff have
carefully considered your comments and we plan to modify the study plan to include analysis for fluoride,
sulfide, and ammonia. We would also note that we plan to analyze the samples for aluminum as part of the
typical metals analysis. However, we do not think that analysis for the PCB congeners is necessary at
this time. If the samples show detectable levels of PCBs, then we may resample for the congeners at a
later date. Also with respect to the number of samples, we note that Alcoa already took a sample from
August 2008 so this spring sample will give us data from another season. Therefore, we still plan to
collect three samples and a blank sample from each of the four discharges on one date next week. If
Stanly County decides to collect additional samples or conduct additional analyses, we will be glad to
review the data as long as it is made available in a timely manner for our review. Please coordinate your
sampling with Pete Caldwell (919-743-8496) in our water quality lab. I can be reached at 919-733-9646.
Pete will modify the study plan accordingly and send it out soon. Thankx.
Griffin, III, Thomas N. wrote:
Hi, John -- thanks for sending Stanly county the draft sampling plan for DWQ's work next week at the
four APGI dams. I wanted to get back to you on a few points --
First, the County would indeed like to participate in the sampling event and take its own samples.
The County would at least take split samples, and also (as described below) may take some additional
samples.or employ sampling techniques to address additional parameters and media. Thank you (and
Pete) for sending along the sampling schedule, and we will confirm the day or days that we will be
attending. In the meantime, should our folks be coordinating with Pete or you (or both)to make sure
that they can get on board (no pun intended, actually)?
Second, we have some comments on the proposed sampling plan. In essence, if the purpose of the
sampling is to evaluate water quality issues related to discharges from the dams, we believe that (i)
more than one sampling event is necessary, at different times of the year, to properly evaluate the
discharges, (ii) more than one sampling location per dam is necessary, (iii) methods must be employed
to collect enough suspended sediment so that the particulates can be analyzed (again at different
times of the year), and (iv) the list of parameters should be expanded to include likely constituents
of concern, and to include individual PCB congeners. As you can see from the "fish study," and from
the review of that study prepared by Dr. Rodgers, evaluating individual congeners is critical to
understanding the quality of the discharge and the health of the lake system. If those congeners had
not been evaluated in the fish study, substantial water quality impacts would not have been detected.
Also, I am told that one would not expect to find PCBs in water sampled in this fashion, which is
another reason to focus on suspended solids in the discharge.
I have attached below more detailed comments on the sampling study that were prepared by Dr. Rodgers
and his colleagues. We would ask that the study be revised and expanded to incorporate our comments.
Third, I noticed in Pete Caldwell's memo that DWQ will be undertaking a sediment study. I'd be
grateful if you would allow us the opportunity to evaluate that work plan and participate in that
sampling, as well.
Thanks again, John. We appreciate the opportunity to comment and participate, and look forward to
continuing to work with you and DWQ on this matter.
Take care -- Tom
* Comments on study plan *
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Re: Sampling at APGI Project
The study plan is limited in scope, and thus the study would yield limited useful information.
Sampling should be representative of reservoir conditions, including sampling over time and space,
collecting sufficient volume using appropriate techniques, and analyzing for appropriate parameters
using methods with detection limits useful for regulatory purposes. This review is organized into
three main section: (1) sampling methods; (2) parameters of interest; and (3) analytical methods.
Sampling Methods
A single sampling event of discharge waters of the four ALCOA operated reservoirs is proposed. The
primary limitation with a single sampling event, especially this time of year when the reservoirs are
stratified, is that many parameters of interest would not be detected. Many organic compounds would
volatilize from surface water and not be detected in grab samples, especially with low sample
volumes. Analytes such as PCBs and sorbed PAHs would be detected only in analyses of particulates
associated with large volume sampling. Accordingly, large volume sampling (with filtering or
centrifugation of particulates) should be employed in this study plan to accurately represent the
situation. Additionally, metals such as mercury, lead, and zinc are sorbed (attached) to fairly
immobile bottom sediments, and thus not present in surface waters this time of year. when lakes "turn
over" in the spring and fall in this part of the country, contaminants associated with bottom sediments
are re-suspended, and if measured, would provide a more comprehensive characterization of the reservoir
conditions. In addition, sampling one location (e.g., near the discharges) will limit information.
The sampling as proposed only provides a "snap shot" of reservoir conditions (i.e., one place and
time). In order to adequately characterize the discharges, a sampling plan should include collection
of representative samples during multiple events (over time) at multiple locations.
Parameters of Intere
DWQ is proposing to measure the U.S. EPA priority pollutants, residue (total and suspended solids), as
well as total and dissolved fractions of the 11 priority pollutant metals. While the priority
pollutant list contains several parameters of interest in this situation, there are other parameters
specific to aluminum smelting that should be included. These parameters include fluoride, aluminum,
biochemical oxygen demand (5 and 20 days), nitrogenous oxygen demand, ammonia, sulfide, and related
cyanide compounds (such as iron cyanides). In addition, the study should measure the 209 PCB
congeners as opposed to relying solely on the priority pollutant Aroclors.
Analytical Methods
DWQ and interested parties should ensure that analyte detection limits are at sufficient levels for
regulatory use (i.e., comparison of results to water quality standards, human and/or ecological risk
calculations, etc..)
In summary, sampling should be representative of reservoir conditions, including sampling over time
and space, collecting sufficient volume using appropriate techniques, and analyzed for appropriate
parameters using methods with detection limits useful for regulatory purposes.
------------------------------------------------------------------------
* Thomas Griffin, III
Partner
Three Wachovia Center 401 South Tryon Street Suite 3000 Charlotte, NC 28202
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Re: Sampling at APGI Project
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John Dorney
Wetland Program Development Unit
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