August 12, 2008
Stop the Giles County Ash Dump
By David Bernard
Thank you for the strong editorial denouncing the bad science and crooked politics behind the Giles County coal waste dump, ("A superfund site in the making?" July 25).Shortly after the Giles site began accepting coal waste in March, inflow of an aquifer exposed by the project's excavation forced dumping to cease. The planning had failed to reveal basic water movement through the site. This aquifer passes under U.S. 460. The project engineers studied a solution.
A June 13 letter from the engineers to the Department of Environmental Quality shows a new plan full of assumptions and contradictions.
The letter acknowledges "the site is in an area of base flood." They call the aquifer "drainage of surface runoff," though if the drainage passes "through the adjacent roadbed of 460," it is not surface runoff.
The coal waste dump has a berm around the sides exposed to the New River. This earthen berm was supposedly designed to withstand a flood of 1 percent chance in any given year.
A concern has always been that however strong this berm, a larger flood that tops it could erode the 28 feet of coal waste piled above the highest level of the berm. The berm designer stated at a public meeting that his design provided no protection for such a larger flood.
Now we learn that this berm is part of the new "design of the fill area . . . to provide an aggregate drainage path under the fill area and through the containment berm." The berm's purpose was both to protect from flood and to contain the coal waste. Is the berm a barrier or a sieve?
The new plan calls for a layer to be built to duplicate the prior "migration path for subsurface water during wet weather, from the north side of 460." The protective berm would allow water to pass through it whenever the aquifer is flowing.
To allow this water to get from the 460 roadbed to outside of the berm, the coal waste dump builders will lay a stratum that will be above the groundwater, yet below the 250,000 cubic yards of coal waste to be piled above. The original plan did not call for a liner, yet now we will have "geotextile layers for separation."
Would it be reasonable to expect DEQ to review this new plan? Last year I wrote Gov. Tim Kaine with concerns about this project. Secretary of Natural Resources L. Preston Bryant, Jr. responded on Dec. 18, "A professional engineer . . . certified that the project will protect the fill material from inundation or washout. . . . The Giles County Partnership for Excellence Foundation, Inc. submitted all . . . other documentation required."
Bryant said I should call Debra Miller in DEQ's Office of Solid Waste with further questions. In July, Miller said she was aware of the Giles coal waste project but not in detail. She said her office existed to help the regional offices with questions or problems, and no such request had come to her.
An Oct. 12 letter from DEQ Director David Paylor asked me to refer further questions to Aziz Farahmand, the waste compliance manager in the West Central Office. On July 23 I asked for Farahmand's response to the plans outlined in the June 13 letter from the project engineers to DEQ.
He had not questioned the plan's ability to protect water from coal waste contamination or its structural soundness. He said the engineering was to be done by the owner, the Gile partnership.
He further stated DEQ doesn't go into great detailed examination. "DEQ doesn't have the means to do sampling or a hydrological study. We rely on the engineering studies submitted to us," he said. "All we need is a professional engineers' certification."
DEQ has not even investigated the coal waste site.
When I asked Miller how this project could be stopped, she said the DEQ director could issue a finding to stop it.
The sooner the Giles County coal waste dump is stopped the better for Virginians. The health dangers from coal combustion waste, both in water and in the air, are well documented. Real leaders will take a stand against this project.
Bernard of Blacksburg, is water quality chairman of the Virginia chapter of the Sierra Club and conservation chair of Coastal Canoeists, a statewide paddling club.
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