=========== COMMONWEALTH OF PENNSYLVANIA Department of Environmental Protection July 27, 2005
SUBJECT: Treatment Options and Goals I-99 Road Construction Project Centre County
TO: Kevin Kline, P.E. District Executive PennDOT, District 2
FROM: Gary J. Byron Assistant Regional Director DEP / NCRO
The I-99 road construction project resulted in the exposure of native minerals containing high levels of pyritic material. The purpose of this memo is to address pyritic material treatment options for this project and establish a basis for achievement of attainment goals. It is not intended to be an all encompassing technical review of all viable treatment options. It should be used as the framework for future, more in-depth evaluations.
In preparation of this memo, we reviewed the Bauxsol background data, specifically, the information provided by Virotec and the Gilt Edge Mine study conducted by EPA. Additionally, throughout this project we have also reviewed sampling data for areas of concern as well as background data for the receiving waters. This data was collected by DEP personnel and representatives of Skelly and Loy, consultants for PennDOT. Additionally, the construction stormwater permit for this site, PAS 10F079-1R, was also reviewed.
Compounds and parameters of concern linked to the pyritic material and established in the above-referenced permit included: pH, total suspended solids, or TSS, sulfates, alkalinity, arsenic, copper, lead, aluminum (total and dissolved), iron (total and dissolved), manganese (total and dissolved), zinc (total and dissolved), nickel, cadmium, and chromium. These compounds are addressed herein. Additionally, based on our review of the Bauxsol data, cobalt, vanadium, calcium, fluoride, phosphate, chloride, magnesium, sodium, and potassium were included.
The treatment options currently being considered are the use of Bauxsol, off-site placement of the pyritic material, and/or covering material in place with a geo-textile or similar cover. These options are currently being evaluated both individually, and in combination with the each other. If other options are considered in the future, they should be evaluated using the framework established in this paper.
Bauxsol is a commercial treatment product made from red mud, a by-product of the aluminum ore refining process. At the I-99 project there are five potentially viable treatment options using Bauxsol:
direct treatment of water treatment of water via a pond liner coating and crack-filling of cutfaces application to rock fills in place mixing with removed material for offsite disposal, either with or without lime addition
The selection of treatment options and a determination of treatment goals can be grouped by location within a watershed. There are two basic watershed types with respect to this project: the Bald Eagle Watershed and the High Quality Watersheds, namely, Buffalo Run and Waddle Creek. We will address each affected area and possible treatment options and goals by watershed. We wish to point out that the regulatory and logical guidelines addressed herein could apply to any proposed treatment option and not just Bauxsol. However, if different treatment techniques were used, then the list of parameters of concern would be different. For instance sodium, calcium and magnesium would be compounds of concern in the effluent if a more traditional treatment system were implemented. Also, it is important to remember that the permitted surface water limits outlined herein must be met not only for the few months of the pilot test, or for just a couple years, but for the foreseeable future as long as an acid rock discharge (ARD) is occurring. Finally, a ground water discharge is occurring and will continue to occur. This discharge will require a separate water quality permit.
Bald Eagle Watershed
The primary area of concern in the Bald Eagle Watershed is the Buttress/Bifurcation, although pyritic material was also taken to the much smaller Trumbull Batch Plant. The ground and surface waters from a significant portion of the Buttress/Bifurcation area flow to Bald Eagle Creek, which has a designated use of trout-stocking fishery, or TSF. It is not a high quality water; therefore, the antidegradation provisions of Section 93.4c have no applicability. Because the applicable rules and regulations do not preclude leaving the material in place, the use of Bauxsol to both coat and impregnate the material at these two locations may be both a technically and economically feasible as well as environmentally-sound option. If this option is to work, any surface water discharged must comply with the limitations established in Table 1 (attached). You will note that the table includes a reference of “Section 87.102” for TSS and alkalinity. This section regulates discharges from surface mining operations. Although it has no direct applicability to this project, it was used to establish technology-based discharge limits in the stormwater permit. We felt these permit limits would have applicability to any in-place treatment option as Section 93.6 (general water quality criteria) does not allow the discharge of any substances at levels that would be harmful to human, animal, plant or aquatic life.
Based on the list of five Bauxsol treatment scenarios, application to the rock fills in place may be the easiest option to maintain. Under this treatment scenario, it is possible that some of the total rainwater flow used to calculate some of the limits in Table 1 might bypass the pyritic materials. To account for this reduced flow scenario, we have included Table 1a (attached). This table shows the discharge limits assuming an 80% reduction in flow of water affected by pyritic materials. It is important to note that the 80% reduction was not selected based on any scientific data, it was selected strictly to provide an example of how the discharge permits would change with a reduction of flow. Other Bauxsol treatment options would include total collection of all contact water with either direct or pond treatment and eventual discharge to Bald Eagle.
With respect to attainment goals, any of these in-place treatment schemes must meet the permit limits referenced above. These limits are established by regulation as non-polluting limits. If no in-place treatment option could meet the above limits, then either the treatment chosen could be combined with collection and additional treatment of any surface water discharge, or a non-discharge alternative for the water would need to be implemented, and/or removal of the pyritic material would have to be considered. Non-discharge alternatives will be discussed in more detail later in this paper in the sections outlining the high quality watershed requirements.
High Quality Watersheds –General Requirements
Both Buffalo Run and Waddle Creek have a designated use of high quality-cold water fishery, or HQ-CWF. Any discharges to these waters are subject to the provisions of Section 93.4c (implementation of antidegradation requirements). Non-discharge alternatives must first be evaluated, and utilized if they are environmentally sound and cost effective. If there are no such non-discharge alternatives, the next allowable option is a discharge alternative, at a quality and quantity, which will not statistically change the existing quality of the receiving stream. This option is referred to as the “non-degrading” discharge alternative. The third option is a discharge alternative, at a quantity and quality that meets water quality based limits. This third alternative is referred to as the “degrading discharge” alternative. “Degrading discharge” alternatives are allowable only if there is an adequate social and economic justification, or SEJ, for the activity causing the degradation. We wish to point out that even if an SEJ can be obtained for this part of the project, any final discharge permit limits cannot exceed those established under Section 93.7 and Chapter 16. In other words, any discharge must be non-polluting. We will now discuss how these regulations will affect the potential treatment options based on the type of material, i.e., movable or immoveable.
High Quality Watersheds – Movable Materials
The following locations of pyritic materials have been identified as “movable”: Skytop fill, 3042 fill, Siebert fill, 317 fill, Sellers Lane fill, a structural fill adjacent to the Arbogast fill, and portions of the Buttress/Bifurcation fills within the Buffalo Run watershed. For the purposes of this memo, we define the term “movable” to mean pyritic material that can be removed from its staged location without causing long-term environmental harm, loaded onto a hauling vehicle, and moved from the high quality watershed. This definition also resulted in portions of the Buttress/Bifurcation fill that need to remain in place to prevent further hillside collapse being classified as “immovable” (please see the next section of this memo). For the locations listed in the first sentence, above, the regulations would identify the physical removal of these materials as a non-discharge alternative. The only way the materials could be left in place would be if removing them would be less environmentally sound then leaving them in place or if PennDOT could show that the removal of these materials would cost more than a discharge alternative. With the exception of portions the 317 fill, we feel that it would be difficult, if not impossible, to justify leaving the materials in place on the basis of environmental soundness. Additionally, for those portions of fills immediately adjacent to major concrete structures, DEP recognizes that the removal of said material could compromise the integrity of the structures. If PennDOT intends to leave any such fill material in place, they will need to provide appropriate justification.
Other potentially viable non-discharge alternatives would be to allow the materials to remain in place and either fully encapsulate them so as to prevent water from coming into contact with the pyritic materials and/or completely divert the water from these areas from the high quality stream. The diversion of the discharge water away from the stream, i.e. the non-discharge alternative, could be accomplished by, among other options, collecting all of the surface water discharges and then transporting the water out of the watershed for treatment at an approved facility, or by discharging water collected and treated on-site into a constructed wetland with a groundwater discharge. Note that the last option above would require a water quality permit for the discharge to groundwater. There are potentially many technical and economic barriers to these alternatives and any analysis would be beyond the scope of this memo. PennDOT would have to evaluate the environmental soundness and costs of such proposals.
Assuming PennDOT can show that there are no viable non-discharge alternatives, the above materials could be treated with a combination of Bauxsol treatment options. For example, the materials could be mixed and coated with Bauxsol. Additionally, any runoff could be collected, treated further with Bauxsol and then discharged to the high quality waters. Any of these options would be discharge options and, as such, would have to be non-degrading. The non-degrading limits for any discharge to Buffalo Run or Waddle Creek are listed in Table 2.
Should Bauxsol be unable to provide treatment of the parameters of concern down to the non-degrading levels, PennDOT would have to then go through the SEJ process as addressed in the antidegradation regulations. If the SEJ were approved, the final discharge limits would fall somewhere between non-degrading and non-polluting, with the least restrictive limits being the non-polluting limits as listed in Table 3 (attached).
In the previous section, the limits in Table 1 were revised after accounting for a scenario that included reductions in flow. These revised limits were listed in Table 1a. The limits established in Tables 2 and 3 cannot be revised in the same manner, as they are not flow dependent. The non-degrading limits were derived based on a statistical analysis of the background concentration data for Buffalo Run and Waddle Creek; therefore, regardless of flow, the limits would be the same. The non-polluting limits were taken directly from Chapter 16 as the discharges are at the headwaters of the respective stream. In other words, there is no dilution simply because the “discharge” flow and “upstream” flow are one in the same.
Should Bauxsol be unable to achieve compliance with the non-degrading limits, or in the case of an approved SEJ, something less stringent than the non-degrading limits, then PennDOT would have to either consider another treatment technology or remove the materials from the high quality waters, regardless of cost.
High Quality Watersheds – Immoveable Materials
The following locations of pyritic materials have been identified as “immovable”: the large cutface, the cutface on the opposite side of the highway from the large cutface, the small cutface, all other rock cutfaces, and the portions of the Buttress/Bifurcation within the Buffalo Run watershed that need to remain for reasons of structural stability. For the purposes of this memo, we define the term “immovable” to mean pyritic material that, for all practical purposes cannot be removed from its location, for example, exposed bedrock. Additionally, based on previous discussions with PennDOT, and the review of the geotechnical report on the problems associated with removal of the Buttress/Bifurcation, DEP has agreed that the portions of the Buttress/Bifurcation that are needed to retain structural stability of the hillside do not need to be moved. Going through the antidegradation process as in the previous section, we feel that for these sites it would not be possible to remove all of the pyritic material and removing some of it could result in an even greater amount of exposed surface area of pyritic material. PennDOT would have to conduct its own feasibility analysis; however, we feel that removing the above materials would not be environmentally sound and thus not a viable non-discharge alternative.
Potentially viable non-discharge options would include the options discussed above in the High Quality Watershed – Moveable Materials section. Again, the technical and economic ramifications of these options are complex. PennDOT would have to conduct its own evaluation.
As far as any discharge alternatives, the rationale, discharge limits, and conclusions would be the same as those discussed in the previous section.
Groundwater Discharge
Based on the groundwater sampling results collected to date, most of the fills/cuts have produced discharges of ARD to the groundwater. As mentioned above, with respect to the groundwater discharges, there are two potential scenarios that would require a Water Quality permit. The first is the ongoing discharge from the project that would be expected to continue to occur, albeit at a reduced level into the future. The second is if a surface water non-discharge alternative was selected that would include discharge to the groundwater. A standard for groundwater would be developed by selecting the lower of the drinking water standard for groundwater or the contaminant level in the groundwater that, after accounting for dilution, would not exceed the permitted surface water criteria when the groundwater discharged to the stream (groundwater to surface water standard). The drinking water standard would be the same regardless of watershed. These standards are in Table 4 (attached). No groundwater to surface water standards were calculated herein due to the number of cut and fill areas. Any such calculations would need to be performed for each fill area.
Summary
Based on the above analysis, we feel the use of Bauxsol in a discharge alternative for materials deposited within the Bald Eagle watershed is a viable option only if the technical merits of Bauxsol can be justified. The movable materials within the High Quality Watersheds will have to be removed from these watersheds unless PennDOT can either verify that the costs would be prohibitive, or develop other non-discharge alternatives. Immovable materials may have to remain in place with some kind of discharge alternative, either non-degrading or, non-polluting with an approved SEJ. Finally, if Bauxsol or other treatment schemes prove to be ineffective, other treatment and removal options will need to be put forth, evaluated and implemented.
angussux - 15 Aug'05 - 11:22 - 1778 of 1788 edit
looks like the goal posts are in bauxsols favor
bros1 - 15 Aug'05 - 12:07 - 1779 of 1788
below says it all :
Bauxsol is a commercial treatment product made from red mud, a by-product of the aluminum ore refining process. At the I-99 project there are five potentially viable treatment options using Bauxsol:
direct treatment of water treatment of water via a pond liner coating and crack-filling of cutfaces application to rock fills in place mixing with removed material for offsite disposal, either with or without lime addition
Scaleyman - 15 Aug'05 - 12:46 - 1780 of 1788
Welcome back bros1! :)
bros1 - 15 Aug'05 - 14:06 - 1781 of 1788
thanks Scaleyman, I was thinking only taxman could miss me :)
bros1 - 15 Aug'05 - 14:56 - 1782 of 1788
water getting more and more important
State gets money to reduce water conflicts Posted at 3:16 p.m. Aug. 14 By the Associated Press
HAVRE - Montana is one of six Western states getting federal money to cut down on water conflicts.
The state's $81,000 from the Bureau of Reclamation will go toward equipment allowing officials to monitor how much water is being taken from the Milk River along the Canadian border. The river is part of a long-running water dispute between the U.S. and Canada.
Former Gov. Judy Martz asked for a review of the 1909 treaty requiring that the St. Mary and Milk rivers be split equally between the two countries, alleging Montana irrigators were not getting their fair share of water. The International Joint Commission has appointed a commission to study the matter.
The grant money, which came from the bureau's new Water 2025 program, will be used to buy streamflow gauges for the Milk River and its tributaries, develop a computer model of both rivers, and use satellite imagery to verify how much water is being consumed in Canada before the Milk River flows back into Montana.
"It's to get a more accurate picture of the amount of water flow," Bureau of Reclamation spokesman Todd Dixon said.
alanrussell - 15 Aug'05 - 18:05 - 1783 of 1788
A fascinating report, many thanks for posting bros1.
1. It looks as if substantial amounts of the pyritic material are going to be moved away. The door is open if Bauxsol lives up to our hopes but the sentence ".... it would be difficult, if not impossible, to justify leaving the materails in place on the basis of environmental soundness" indicates the thinking. Presumably if it is to be moved it will be to a location that will not pollute watercourses (does such a place exist?) so no treatment is necessary. 2. A earlier report seemed to indicate that Bauxsol was included in parallel testing with lime & mag.sul. as if they were equally promising candidates. This report plainly places Bauxsol at the forefront of options as the preferred treatment. 3. The report provides very a encouraging scenario, as IMHO it is clear that PennDot are very very keen to see Bauxsol succeed. The reason can only be that Bauxsol provides by far and away the most cost effective solution to ARD and PennDot and other public bodies in the state have many other problem sites to deal with. While PennDot being that keen does not affect Bauxsol's prospects of delivering as hoped, it is reasonable to conclude that success at I-99 will lead to a rapid take-up elsewhere. 4. All of which brings us back to where we started. Will Bauxsol succeed? We know the company have stated that at Gilt Edge it worked with as bad and worse contamination but ground conditions are the big variable.
I believe I am right in saying the results are expected to start to become available in September. Presumably commercial considerations will keep everyone tight lipped. Good news in November? Fingers crossed.
alan russell - 15 Aug'05 - 19:15 - 1784 of 1788
Just released - look at the anticipated spend!
New research ties arsenic to tumor growth Posted 08/09/05
.....A recent study on the effects of environmental arsenic at the University of Oklahoma Health Sciences Center indicates that arsenic in drinking water can both stimulate the growth of cancerous tumors and cause them to spread faster. .....While researchers still do not know whether arsenic in drinking water increases the overall incidence of tumors, the study shows that arsenic levels as low as four parts per billion can stimulate blood vessel growth, and levels as low as 10 ppb cause tumors to expand. Many previous studies have linked arsenic ingestion and cancer — especially skin and bladder cancers. .....This report comes at a time when water systems across the US are struggling to conform to a new current federal arsenic standard of 10 parts per billion (ppb) by January 23, 2006. The previous standard had been 50 ppb. In the state of Oklahoma alone, it will cost between $55 billion and $163 billion to replace or upgrade the 25 systems to address the lower arsenic standard. .....When water containing arsenic is ingested, the arsenic reacts with oxygen to create “free radicals” — highly reactive molecules — that stimulate the growth of blood vessels. More blood vessels result in an increase in blood supply to any tumors, which then grow faster and larger. .....Some scientists have suggested that even the new standard of 10 ppb is too high, and California considered setting the cap at 4 ppb. .....Existing, proven POU/POE home products (point of use/point of entry) can reduce arsenic levels in water to below 4 ppb.
For Arsenic (+3) WQA recommends treatment with: • Chemical Oxidation/Disinfection followed by Arsenic (+5) treatment technologies
For Arsenic (+5) you can treat water with: • Iron-based or ioron doped arsenic treatment media • Anion Exchange • Activated Alumina • Reverse Osmosis • Distillation • Electrodialysis • Other speciality media for arsenic treatment
For Arsenic (organic complexed) treat water with: • Carbon Filtration.
.....Not all parts of the country have naturally occurring arsenic in the water. Consumers should check with a water treatment specialist and/or their municipal water system operators or county extension office. WQA urges those on private wells to have their water tested for arsenic and other possible contaminants.
alan russell - 15 Aug'05 - 19:25 - 1785 of 1788
PennDot considering Bauxsol at another site:-
Stabilizing slope priority in black shale treatment Michael Dawson Sentinel Reporter
LEWISTOWN — The Pennsylvania Department of Transportation continues to devise options for treating acidic black shale found last year on the U.S. 22/522 bypass project in Granville Township. But a PennDOT official said Wednesday the center of attention rests with stabilizing the slope in which the shale was found, a slope that became unstable after tropical storms in September 2004. “The primary focus right now is the rehabilitation of the slope that contains the pyritic material,” said PennDOT’s local project manager, Daniel Sokoloski.
The pyritic material — black shale — was found by state highway construction crews in August 2004. PennDOT said in September 2004 that the shale caused acidic stormwater runoff but posed no threat to residential wells in the area. Stabilizing the slope means removing the black shale, said acting PennDOT District 2 Executive, Kevin Kline, who took over for retired district executive George Khoury on Sunday. “What we’re looking at, again, is cutting that bank away and laying the slope back,” Kline said on Tuesday. “With that, we’ll get the majority of the (black shale) out of the there.” Sokoloski said the stability of the slope “is necessary to finish” the U.S. 22/522 bypass project.
After the black shale is removed, PennDOT plans to neutralize it by mixing it with limestone. The mixed material then will be deposited in the bypass project’s 2-million-yard-sized waste area, where materials inside it have a high pH balance, Kline said. That will keep the materials neutralized. On Tuesday, Kline said PennDOT hopes to have approval from the Federal Highway Administration (FHWA) this week regarding its proposal to stabilize the slope on the U.S. 22/522 bypass project.
In addition, the Pennsylvania Department of Environmental Protection has been involved with the black shale issue since the shale’s discovery. The department has monitored the situation to assure no residential wells become contaminated. John Repetz, a spokesperson for DEP, called removing the shale to stabilize the slope “the key to correcting the situation.” He added “there have been no problems discovered” after further well testing for contamination. However, PennDOT does not know when the corrective slope stabilization measures will be taken. “No concrete time frame is in place, but we are working as quickly as we can,” said spokesperson Marla Fannin. Kline added PennDOT wants to “stay out of anything that will cause permanent treatment.”
Additionally, PennDOT may consider using a product called Bauxsol that removes minerals from water. Kline said it is nicknamed “red clay.” Similarly, Bauxsol was considered for the mitigation of the acidic drainage on the I-99 project in Centre County.
In Mifflin County, PennDOT continues to treat stormwater runoff and monitor local wells adjacent to the U.S. 22/522 project site. Cold temperatures have kept water frozen, hindering the process. However, officials expect it to pick up once the snow melts. DEP continues to monitor the situation, and it has an inspector who visits the site to compare testing and other data taken by PennDOT, Repetz said.
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