Monday, January 18, 2016

Possum Point Update

Last Thursday at an all-day meeting in Richmond, the Virginia State Water Control Board approved Dominion Power’s permits to drain its coal ash ponds at Possum Point Power Station in Prince William County (as well as permits for its Bremo Power Station in Fluvanna County). Previously, Dominion Power had submitted three successive permit modification requests for their coal ash ponds at the Possum Point Power Station on June 30, 2014, December 22, 2014, and August 18, 2015. At the Possum Point Power Station. The previous permit requests were modified to reflect the coal ash pond closures so the only remaining permits cover two storm water outfalls SI07 and SI08. These permit requests were made and approved despite no analytical data existing for either stormwater outfall S107 or S108 (per Dominion Power permit request).

Outfall SI 07 collects storm water from coal ash Pond D and under the existing permit was characterized as a non-industrial stormwater outfall. Collected stormwater is discharged to Quantico Creek. Dominion reports that this outfall collects groundwater infiltration from toe drains associated with coal ash Pond D. The drainage area is approximately 14.4 acres of permeable plant ground cover.

Outfall S108 is a new storm water outfall that discharges to an unnamed tributary of Quantico Creek, located south of coal ash Pond E. This outfall is located at the point of convergence for runoff from a VDOT culvert and the culverts containing the station's former ash sluice lines. The drainage area is under an acre of mostly permeable surfaces.

Possum Point Power Station is owned by Dominion Power. It sits on a 650-acre site located in Dumfries Virginia in the eastern part of Prince William County that borders the Potomac River and the Quantico Creek. Dominion Virginia Power has not burned coal at Possum Point for 13 years and is unlikely to burn coal to generate power in the future, but 3.7 million cubic yards of coal ash remain from the historic burning of coal.

Ash Ponds A, B, and C are currently being decommissioned. One million cubic yards of coal ash from those ponds is being moved into Pond D, a 120-acre pond that already contains 2.6 million cubic yards of coal ash. Coal ash Pond E is presently being decommissioned and replaced with a treatment system, as required. Dominion Power is proceeding with a plan to “close in place” the 3.7 million cubic yards of coal ash by consolidating and dewatering the coal ash into a coal ash pond they claim is lined (as required by regulations) which will then be capped with an impermeable membrane to prevent infiltration of rain in the future. These old coal ash ponds have been open to the elements and taking on water for decades as well as being in contact with shallow groundwater as was disclosed in the permit applications and modifications.

It is possible that trace contaminants including metals (and potentially hexavalent chromium) in the coal ash have already leached into the groundwater, Quantico Creek and Potomac from the coal ash ponds. Permanently disposing of the coal ash on site, when properly done, can be protective of the environment and water resources, but requires a liner separating the coal ash from the groundwater and ongoing monitoring and maintenance. All physical barriers fail over time this is addressed by the monitoring and maintaining the systems required by the regulations.

The State Water Control Board that approved the permits is composed of seven Virginia citizens appointed by the Governor, and is responsible for oversight of the Virginia Pollutant Discharge Elimination System Permit (VPDES permit) under section 402 of the Clean Water Act that established the program to limit pollutant discharges into streams, rivers, and bays. In the Commonwealth of Virginia, DEQ and the State Water Control Board administer this program by issuing VPDES permits for all point source discharges to surface waters.

The US Environmental Protection Agency (EPA) maintains authority to review applications and permits for "major" dischargers, a distinction based on discharge quantity and content. Several groups have raised concerns with the plan and the speed with which they are proceeding without community involvement and input. Most importantly, the Southern Environmental Law Center and the Potomac Riverkeeper Network contend that the large pond where they are consolidating all the coal ash is only partially lined. The Potomac Riverkeeper Network plans to file a lawsuit to have the permit revoked, believing that the permit does not comply with the requirements of the Clean Water Act. (In the interest of full disclosure I was once a member of the Hudson River Fishermen’s Association a predecessor of the Hudson Riverkeepers, and I volunteer with the Prince William County Rural Household Water Quality Program.)

The finalized EPA regulation for coal ash requires that coal ash disposal site must have protective liners to prevent groundwater contamination. The rule also requires companies to conduct monitoring of disposal sites, clean up any existing contamination, and close and remediate unlined disposal sites that have polluted groundwater. Finally, monitoring data, corrective action reports, and other important information about the site must be made available to the public.

Dominion’s closure plan should include additional site investigation to demonstrate to the stakeholders in the community that the liner in coal ash Pond D is sound. In addition it is essential that testing of groundwater, surface water sediments, and the water treated at the outfalls be done for a broader spectrum of contaminants to better protect the environment and determine the extent of impact if any from the decades storage of the coal ash on site. Though Possum Point is downstream from nearby drinking water supplies and is unlikely to impact local residents beyond what has already taken place over the decades; however, the current level of impact needs to be investigated and monitored for the 24 nearby private wells.

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