Ohio EPA Letter

CLERMONT BOARD OF COUNTY COMMISSIONERS GOUN Tyo __DAVIOL. PAINTER - CLAIRE B. CORCORAN » BONNIE J. BATCHLER WATER RESOURCES DEPARTMENT es July 13,2023 Russell Brown, Ohio EPA Southwest District Office 401 East Fifth Street Dayton, Ohio 45402-2911 Russell, [email protected] Subject: May, 2023 In-Situ Treatment Proposal for the former Walter C. Beckjord Station, New Richmond, Ohio Dear Mr. Brown, Clermont County continues to have serious concern regarding the management of the closure of the unlined and leaking surface impoundments and the ongoing migration of contaminants in groundwater from the coal ash impoundments at the site of the former Beckjord coal burning power plant. These contaminants continue to threaten one of the County's primary public water well fields. Due to this threat, we again request to be apprised of any plans, activities, or discoveries at the site which could impact the drinking water supply and be provided the opportunity to review and express our concerns (or support) of said plans, activities, or discoveries. On May 26, 2023, the Ohio EPA Division of Drinking and Ground Waters approved a plan, submitted by Gemini Environmental on behalf of New Richmond Development Corporation (NRDC) on May 25, 2023, to inject sodium lactate and sodium acetate into the groundwater in an effort to perform in-situ treatment of the sulfate plume originating from the coal ash surface impoundments. This plan is very similar to the plan submitted in May of 2021 by Key Environmental on behalf of NRDC. On June 9, 2021, Clermont County provided a letter identifying significant concerns associated with this plan. Ultimately, the plan was not approved by the Ohio EPA and we were unaware of NRDC’s efforts to resuscitate it. Obviously, we are concerned and confused as to why the agency would now approve the plan, particularly without any effort to notify Clermont County of this injection activity directly upgradient from the public water supply and despite our repeated requests to be notified in advance of changes or additions to the already insufficient NRDC closure plan. Clermont County continues to have concerns related to the most recent plan (May, 2023) submitted ‘on behalf of NRDC. These questions and concerns are as follows: Both the 2021 and 2023 In-Situ Treatment proposals use sodium lactate and sodium. acetate to promote biological attenuation of sulfate. The 2021 proposal included Table 1, which listed various analytes and how their concentrations were affected following the lactate/acetate addition and following addition of an oxidant. A similar table was not included in the 2023 proposal. Therefore, on page 9 of the 2023 proposal, Clermont County requests to expand the specific target analyte list to: sulfate, antimony, arsenic, barium, boron, chromium, iron, lead, magnesium, manganese, mercury, molybdenum, sodium, and. Total Organic Carbon (TOC). 513.732.7970 4400 Haskell Lane Batavia, OH 45103 www.ClermontCountyOhio. govJuly 13, 2023 Page Two 2, The 2023 In-Situ Treatment proposal does not identify the design of the proposed treatment injection well. The design should be identified to help determine if the lactate acetate injectant will be captured within the screened zones of the two proposed monitoring wells. We also recommend that NRDC provide the agency with “as-built” information confirming the well depth and screened interval. 3. Consideration should be made for development of the new injection well and init the lactate/acetate injection. The geochemistry ofa newly developed well may be significantly different than the aquifer. 4. The 2023 plan does not mention ifa unique tracer dye will be used with the lactate/acetate injection. How will the occurrence of the augmented injectant water (in time and concentration) at the monitoring wells be identified? 5. According to the research article that was submitted to ACTA and attached to the 2023 plan, the sulfate reducing bacteria that will be formed by the lactate/acetate injection will reduce the sulfate to hydrogen sulfide. Is having the groundwater contaminated with hydrogen sulfide any better than sulfate? This proposal also acknowledges that concentrations of soluble metals may occur. Will this really be a benefit to water quality? jon of Although it is unclear what the final intent of the in-situ treatment proposal is, the Clermont County Water Resources Department feels strongly that long term ground water monitoring and operation of the interceptor well(s) must continue indefinitely. Long term monitoring and interceptor well operations along with the financial assurances to provide the necessary funding for this work are of paramount importance and we are relying heavily on the Ohio EPA to help protect our interests. Sincerely, FY J3- Bloom Lyle G. Bloom, P.E. Director of Utilities Ce: Bonnie Buthker (via email) Glen Vonderembse (vial email) Todd Anderson (via email) Scott Doran (via email) Clermont County Commissioners Tom Eigel Greg Bickford 513.732.7970 4400 Haskell Lane Batavia, OH 45103 www.ClermontCountyOhio. gov

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