The Giles County Board of Supervisors received, at its regular board meeting of April 23, 2009, data from water testing at two wells located near the site of the Cumberland Park Project. The results were presented by an activist group known as the “Concerned Citizens of Giles County.”
After reviewing the data, it is apparent that the information contained therein cannot be considered reliable.
A review of the testing follows, which is at best inaccurate and incomplete.
- The final report does not indicate how samples were protected from contamination, what types of quality control measures were in place, the methodology used, and whether important data such as temperature and pH were taken into consideration. In addition the report is lacking a signature and includes portions that are hand-written and unreadable.
- In comparison to the report prepared by the firm of Draper Aden, for the Cumberland Park Project, this report is lacking in nearly every aspect of professionalism and credibility.
- The Draper Aden report, prepared after a year of scientific research, and presented in proper context, found no significant harmful indicators from the Cumberland Park Project. This is consistent with findings from numerous inspections by the Department of Environmental Quality.
- Any report on water quality or other environmental factors related to the Cumberland Park Project must be gathered, tested and presented professionally and according to the highest standards. Only then can a valid comparison be made to The Draper Aden studies performed by the Cumberland Park Project.
Response to Report
"After reviewing the information, we agree with AEP’s comments in that significant procedural information such as chain of custody documentation, QA/QC data and discussions, sampling methodologies, well location data, and complete laboratory data packages were all lacking from their presentation that would support the validity of the data and enable evaluation of the data. It is impossible to make a statement or judgment regarding the value of this data, trends in the data, or comparisons with regulatory limits based on the information presented.
In addition, we stand by the statement that groundwater data collected to date by Draper Aden Associates in wells MW-1 and MW-2 has revealed no indication of impact to groundwater caused by the placement of the coal fly ash at the Cumberland Park Site"
DRAPER ADEN ASSOCIATES - May 8, 2009
The laboratory analysis report submitted by the Concerned Citizens does not indicate contamination of groundwater caused by the placement of coal ash structural fill at the Cumberland Park Project site.
Many of the necessary procedural steps, in producing valid and defensible samples and levels of constituents, were not executed or identified in this report. The report lacks standard data verification information, thus the results can only be considered provisional at best. No information is presented that indicates, definitively, contamination. In addition to the lack of defensible analysis results, there is not enough data to identify any increasing trend indicative of contamination from the structural fill, e.g. it is not possible to perform statistical analysis of the data.
Of the constituents which were analyzed, only one (lead) exceeded US EPA’s Maximum Contaminant Level for safe drinking water. It should be noted that lead is not a constituent which is representative of ash leachate and has been found to occur in uncontaminated groundwater at or above the levels in this report.
The following issues should be addressed prior to any additional sampling of these wells:
- There is no chain of custody associated with either of the Final Reports. The chain of custody should indicate information such as the preservation methods, corresponding sample identification, and appropriate signatures by the party responsible for the sampling as well as the lab personnel receiving the samples.
- The sampling report does not include appropriate quality control and quality assurance measures (QA/QC) such as trip blanks, lab blanks, duplicate analyses, and matrix spike and recovery analyses. These QA/QC measures were taken and reported in the 2008 annual groundwater monitoring report issued by Draper Aden.
- No specific sampling methodology is identified. If the wells were bailed, were three well volumes removed and “fresh” water from the aquifer allowed to recharge the well? This would provide a more accurate depiction of the formation water. Also, if bailing was the sampling method used, was the equipment decontaminated between sampling events.
- Was indicator data collected? Indicator parameters such as temperature, pH, and conductivity are used to ensure stabilization of groundwater prior to sample collection. All three of these parameters were measured during the sampling events for Draper Aden report.
- No bore logs or well logs are included with this report. A bore log would indicate the different types of material encountered during the drilling for the well holes. The well log would provide data for the well’s construction indicating the depth of the well and the interval over which it is screened. This information is necessary in understanding what is being sampled.
- On two occasions, the analysis result of mercury is reported to be equivalent to the analyte reporting limit. Without adequate QA/QC data, these results must be regarded as skeptical. For all samples, the Method Detection Limit (MDL) should have been indicated for each parameter analyzed.