tag:blogger.com,1999:blog-6470042404024962381.post995031477608042227..comments2023-09-12T08:52:59.939-07:00Comments on TVA Coal is Killing Tennessee: TVA ARAP PERMIT--please comment and request hearingUnknownnoreply@blogger.comBlogger2125tag:blogger.com,1999:blog-6470042404024962381.post-1829489874209270972009-02-13T18:25:00.000-08:002009-02-13T18:25:00.000-08:00I just noticed not noticing something: There are c...I just noticed not noticing something: There are continuous sampling points, and a list of things they'll sample, but see which of those conditions they'll be sampling continuously: <BR/><BR/>“Turbidity, temperature, dissolved oxygen, conductivity, and pH”. There is NO mention of continuously monitoring for dangerous levels of the elements they’re supposed to be watching. If there won’t be continuous monitoring for those, there should be monitoring on a random schedule to avoid bias. If you’re not avoiding bias, it’s not scientific.Calumnyhttps://www.blogger.com/profile/08997890048666025318noreply@blogger.comtag:blogger.com,1999:blog-6470042404024962381.post-44848458064490676222009-02-13T16:22:00.000-08:002009-02-13T16:22:00.000-08:00Re: TVA Emory River Dredging Plan, Kingston Fossil...Re: TVA Emory River Dredging Plan, Kingston Fossil Plant Ash Recovery Project.<BR/><BR/>----------------------------------------<BR/><BR/>Assumptions before reading; compare to the actual document so I can boast:<BR/><BR/>I'll look at the thing if you send it, but will make a daring prediction that it will be some vague, longwinded POS copied & pasted from an old policy statement or procedural guideline. Of course, you'd want some more specific judgment than that.<BR/><BR/>'Course, considering what POS stands for, you may consider me prejudiced....<BR/><BR/>The trick, aside from getting TVA off their collective bureaucratic hineys to do anything at all while there is still time to make a difference, will be how to remove the dreck without stirring more water through it and releasing more contamination. Hydraulic (suction) dredging is definitely to be avoided, at least without some sophisticated filtering system, because it does exactly that. Think of a very large wet/dry shop vac, on a barge... [or if you have ever used one of those aquarium vacuums that suck gunk off the gravel while returning the water to the tank, that’s the principle too].<BR/><BR/>I point out, before reading, that the spill is into the upper reaches of a TVA reservoir (Watts Bar Lake), so they CAN lower the water level if they really want to, and bulldoze instead of dredge. Alas, the plant that turned out the fly ash in the first place probably needs the high water level to function and its operation is clearly TVA's top priority. Other problems for using this method include complaints from lakeside residents & businesses, and the facts that letting the ash drain by any method will let contaminated water seep out of it, and that much of the ash will have settled into the old watercourse, which will reactivate and tend to wash away the deposit when the water level is lowered. <BR/><BR/>Possibly the best containment method would be to build a new berm isolating the contaminated area (which will continue to grow until something is done) or at least the most contaminated area, during cleanup. This would probably cost more than building the lake in the first place. Betcha anything that's why TVA is waffling & weaseling and not talking about best management practices or best available technology. And we already know how well they build berms.<BR/><BR/>To paraphrase: 'When a can of worms is opened, it is possible to seal them up again, but it takes a bigger can'. In this case, probably a much bigger can.<BR/><BR/>-----------Notes from actually reading the thing, page 1 - 2 -----------<BR/><BR/>The Emory River’s channel seems to be the whole object of “The Phase 1 Dredging Plan”. The real object is probably to be able to claim that they have a plan.<BR/><BR/>Neither phase of the plan cleans up anything but the channel, which is underwater anyway because it’s an inlet of Watts Bar Lake. They admit this on page 2 – 1, where they call it Watts Bar Reservoir.<BR/><BR/>Forget the legacy sediments; they’re irrelevant relative to the contaminated ones. <BR/><BR/>Yep, they’re going for “primarily hydraulic dredging”. <BR/><BR/>-----------Notes from actually reading the thing, page 1 - 4 -----------<BR/><BR/>Gotta love the way they have columns headed “early start” and “early finish”, and are still installing liner in the temporary storage area throughout March. As long as they are still building the storage area, they’re not using it. I see no actual start for the (token) dredging.<BR/><BR/>-----------Notes from actually reading the thing, page 2 - 1-----------<BR/><BR/>They mention a need for more dredging, not specified. <BR/><BR/>-----------Notes from actually reading the thing, page 3 - 1 -----------<BR/><BR/>Erosion control is good. Last month would have been better.<BR/><BR/>-----------Notes from actually reading the thing, page 5 - 3 -----------<BR/><BR/>Finally, mention of Best Management Practices… but for the dewatering, meaning placement of the dreck they plan to actually move.<BR/><BR/>-----------Notes from actually reading the thing, page 5 - 4 -----------<BR/><BR/>I’d really like to see monitoring of the return water. What are they letting run back into the lake? <BR/><BR/>-----------Notes from actually reading the thing, page 5 - 5 -----------<BR/><BR/>Interesting list of elements; darned if I know how they chose those amounts, though. Some of those will be really easy to keep below toxic levels, for example iron, which does not dissolve in oxygenated water at anywhere near dangerous concentrations. Others are cumulative poisons and dangerous at nearly any measureable concentration.<BR/><BR/>-----------Notes from actually reading the thing, page 6 - 1 -----------<BR/><BR/>The health & safety plan only refers to workers. Um, how about residents? Recreational users? People downstream? People eating fish? Looks like a token legal minimum, to me. Now they can tell everyone that they have a health & safety plan.<BR/><BR/>-----------Notes from actually reading the thing, Figure 9 -----------<BR/><BR/>Whaddaya know, the continuous sampling location closest to the spill will be at the plant’s water inlet. <BR/><BR/>-----------Notes from actually reading the thing, generally -----------<BR/><BR/>What’s the obsession with restoring the original channel instead of the original water chemistry? Since when is legacy sediment a priority to anyone? Answer: When preserving legacy sediment is the easiest standard to meet. Look, they have a conservation standard.<BR/><BR/>Good news from the pictures is that if they put a new channel through the sand bar just NE of the main spill, it will divert current away from the spill and allow better containment around the main spill area during a thorough cleanup. Bad news is that they specifically plan not to do that.<BR/><BR/>Why is it such a total pain in the ass to comment? Don't you want comments? Betcha that's why I'm the first.Calumnyhttps://www.blogger.com/profile/08997890048666025318noreply@blogger.com