Bridges Authority Consultant Project Manager responds to badwaterjournal with summary of stormwater containment.     

      Scroll to bottom of page

Louisville Water Company

Barbara Dickens, Esq.

Vice President, General Counsel

& Official Custodian of Records

Beverly Soice

 

Re: Open Records Request 12-27-2010

by email and letter

Copy to:

John Sacksteder, Project Manager

Community Transportation Solutions 

General Engineering Consultant (CTS-GEC)

Forum Office Park III

305 N. Hurstbourne Parkway, Suite 100

Louisville, KY 40222

DEP Division of Water

200 Fair Oaks Lane

Fourth Floor

Frankfort, KY 40601

Ted Pullen

Metro Public Works & Assets

444 South Fifth Street

Suite 400

Louisville, KY  40202

  

Beverly Soice,

Thanks for your courteous response to my Open Records Request. This is a follow up

memo to our appointment, 1-14-2011 at 2:00 pm in the Kentucky River Room. Please forgive

this long post, but I need to set forth my concerns/request  with some supporting documentation.

The materials provided to me so far do not establish that the Louisville Water Company

has quantified or projected  the effect of groundwater contamination that will be caused by a proposed east end bridge along the A-15 route identified in the 2003 Rule Of Decision for the Bridges Project.  

The materials do not indicate that LWC is taking sufficient action to protect groundwater in the WHPA from deicing contamination.

As such, it appears Louisville political leaders and citizens are not being fully and accurately informed

about the threat of road salt salinization of the ground water resources that are critical supply for Louisville's 

drinking water intake at the $55 million dollar artesian well collections area.  Without full and complete information the public and decision makers could elect to place a six lane highway and bridge over the wellhead protection area resulting in the contamination and loss of the drinking water source and waste of $ 55 million dollars invested.

You represented at the meeting in the Kentucky Room that LWC had no groundwater protection monitoring chloride results from the Well head protection area, the WPA zones at the Payne collection area. 

You provided copies of  Na+ and chloride results for testing performed from 2006 to 2008 at the Zorn Avenue facility. 

Examination of that data shows a cumulative increase over the testing period, at water monitoring wells designated ZMW-9A, 9B, 9C. At ZMW-9A.

Chlorides increased over the period September 2006 to March 2008,  from 4900 mg/L to 8700 mg/L.

"There is no maximum contaminant level (MCL) or health advisory level for sodium; however, there is a

Drinking Water Equivalent Level of 20 mg/L (a non-enforceable guidance level considered protective against 

non-carcinogenic adverse health effects). Chloride, for which EPA has established a national secondary drinking water standard of 250 mg/L, adds a salty taste to water and corrodes pipes. It can also cause problems with coagulation processes in water treatment plants. The water quality standard for chloride is 230 mg/L, based on toxicity to aquatic life."

Source Water Protection Practices Bulletin, Managing Highway Deicing to Prevent Contamination of DrinkingWater, USEPA, EPA 816-F-09-008 July 2009, Office of Water (4606).

I was not provided a location for the Zorn ZMW 9A site but I assume it was close to River Road intersection and sensitive to road salt runoff. Does your staff have another interpretation? These Chloride concentrations exceeded  U.S. Environmental Protection Agency (USEPA) acute (860 mg/L) and chronic (230 mg/L) water-quality criteria.

Thus the data provided tend to support the scientific peer reviewed literature that, 

"Studies have shown that road salts can accumulate in streams and ground water, persisting beyond the time of application,  often into the summer months."

"The scientists have found that salt levels (chloride and sodium) at Minebank Run are chronically elevated throughout the year, even in summer when no salts are applied. Chloride and sodium levels are significantly higher downstream of the I-695 beltway, suggesting that this major roadway is a significant source of road salts to ground and surface water in this watershed." 

http://www.epa.gov/ada/eco/pdfs/road_salts.pdf

and,

"The relation of chloride concentrations and specific conductance with urban land use shown in this study and a recent study of the northern United States (23) indicates that road-salt runoff and other anthropogenic uses of chloride are importantfactors in the biological integrity of urban streams in the northern United States. Although chloride sampling has beenincluded in previous evaluations of urban streamwater quality (21), water-quality sampling did not specifically focus onperiods of winter runoff and may not fully represent the severity of road-salt influence."

Steven Corsi, et al., A Fresh Look at Road Salt: Aquatic Toxicity and Water-Quality Impacts

on Local, Regional, and National Scales, Environmental Science and Technology, 2010, 44, 7376–7382. ACS.

This data is of particular concern to protectors of surface water quality in Beargrass Creek if

LWC intends to discharge FILTER BACKWASH at I-64 and Grinstead Drive to the Middle Fork of Beargrass Creek.

The removal of solids from Zorn Avenue pumped water, whether derived from the artesian collection wells or from the Zorn Avenue River intakes would apparently leave a filtrate high in chlorides.

DATA PROVIDED

The sole document provided to me that directly referred to the object of my Open Records request was titled, 

"Proposed Transportation Management Plan"  on Page 10 it reads, 

"Additional Transportation Issues"

"Additional Transportation Issues include the design and drainage plan for the bridge and tunnel to be constructed over the Ohio River, at least part of which will be located within the WHPA (well head protection area). At this time, details of the design for these structures are not available. LWC plans to meet with the state highway department and design engineers to discuss methods of minimizing the potential for contamination as the design progresses. The local Planning Team will be a part of this planning process."

This laconic item is not dated and appears to be an excerpt from a  newer document after the 2003 - 2004 dates of the Wellhead Protection Plan.

Construction of the LWC Riverbank Filtration Project began in March 2007 and was complete in the fall of 2010.  The $55 million dollar investment  has constructed a system that can pump up to 70 million gallons of water a day from the aquifer.

<http://www.louisvilleky.gov/LWC/News/2010/Riverbank+Filtration+Project+Completed.htm>

This tremendous drinking water supply feat of engineering deserves  better protection than a sleepy note that LWC plans to meet with Transportation Dept engineers to discuss minimizing potential contamination. When would that occur?

There is no statement from any qualified engineer or investigator, that a six lane superhighway is even compatible with a 70 million gallon per day drinking water well head area. 

The Riverbank Filtration Project was installed after the 2003 ROD of the bridges project, and after the 2003-2004 Wellhead Protection Plan filed with the Groundwater Branch of the Division of Water.

DIFFERENCE IN WITHDRAWAL RATES USED FOR MAPS AND ACTUAL WITHDRAWAL

The 70 million gallon per day pumping rate does not seem to be a rate used by the ground water protection and well head protection plans filed with the state which show a 17 million gallon per day pump rate. The WHPP does not contain any information that the Riverbank Project could draw 70 million gallons per day. There is no indication that the community or the Planning Area Team was ever informed of corrected WHPA maps calculated to show correct areas that would result from a 70 million gallon per day draw down rate. As a result, contamination by salinity from road runoff may occur at a faster rate than indicated.

A map of the proposed route from the website <http://www.kyinbridges.com/maps-features/default.aspx?ml=4>  shows the proposed route of the A-15 bridge passing directly over the wellhead protection area. 

The Record of Decision discussion of the impacts to groundwater in the well head protection area  is vague and unfocused as it did not contemplate the 70 million gallon per day draw down. 

Nowhere is there a detailed calculation of pollutant loadings to storm water runoff from deicing practices in the wellhead area.

Engineers projected 72,000 vehicles per day of traffic (or more) on the east end bridge alternative. The wellhead protection plan would seem to require new expert opinion and investigation aimed at answering the question:

How many years before bridge and highway pollution forces the LWC to shut down the $ 55 million dollar Riverbank Filtration wells.  Since the wells are linked by a tunnel, the output of the wells would be contaminated even if only the one closest to the bridge began to experience heavy chloride or cyanide pollution. The odds of catastrophic contamination from toxic or hazardous chemicals hauled on the 841 connector bridge are not considered. 

Neither the Kentucky Transportation Cabinet, nor the Kentucky Division of Water has the same investment of public money in drinking water facilities impacted by the proposed east end bridge over the WHPA. 

The transfer of information from your science community to the public and decision makers is failing to fully describe the impact of road salting on drinking water resources and surface water quality.

Please increase the information on your website to communicate this issue and the present THREAT to the community based on your results.

Clarence Hixson

badwaterjournal.com

LWC Data - Test results at Zorn Avenue groundwater test wells ZMW-9A, 9B, 9C

9-19-06        Na(mg/L)     Chloride (mg/L)

ZMW-9A         2900           4900

ZMW-9B        1700            2700

ZMW-9C        1600            2600

9-29-06        Na(mg/L)     Chloride (mg/L)

ZMW-9A         3700           5100

ZMW-9B        1700            2800

ZMW-9C        1500            2500

10-4-06        Na(mg/L)     Chloride (mg/L)

ZMW-9A         2800           5000

ZMW-9B        1800            3100

ZMW-9C        1600            2400

11-14-06        Na(mg/L)     Chloride (mg/L)

ZMW-9A         3200           5300

ZMW-9B        1600            2900

ZMW-9C        1300            2400

12-13-06        Na(mg/L)     Chloride (mg/L)

ZMW-9A         6900           5800

ZMW-9B        1600            2900

ZMW-9C        2800            2100

1-10-07        Na(mg/L)     Chloride (mg/L)

ZMW-9A         3500           6000

ZMW-9B        1900            3000

ZMW-9C        1100            1800

2-14-07        Na(mg/L)     Chloride (mg/L)

ZMW-9A         7400           6100

ZMW-9B         4300            2600

ZMW-9C        1600            2000

3-13-07        Na(mg/L)     Chloride (mg/L)

ZMW-9A         3700           6800

ZMW-9B        1700            3000

ZMW-9C        1200            2100

4-10-07        Na(mg/L)     Chloride (mg/L)

ZMW-9A         4000           7000

ZMW-9B        1800            3100

ZMW-9C        1300            2400

5-15-07        Na(mg/L)     Chloride (mg/L)

ZMW-9A         4400           7500

ZMW-9B        1800            3000

ZMW-9C        1300            1800

6-13-07        Na(mg/L)     Chloride (mg/L)

ZMW-9A         4700           7600

ZMW-9B        1900            3200

ZMW-9C        1000            1800

7-12-07        Na(mg/L)     Chloride (mg/L)

ZMW-9A         4000           7100

ZMW-9B        2000            3000

ZMW-9C        1000            1700

8-14-07        Na(mg/L)     Chloride (mg/L)

ZMW-9A         4300           7700

ZMW-9B           430           3600

ZMW-9C           210           1700

DATA GAP

3-24-08        Na(mg/L)     Chloride (mg/L)

ZMW-9A         4900           8700

ZMW-9B         2400           4200

ZMW-9C        1600            3000

Rule of Decision

LWC website

http://www.louisvilleky.gov/LWC/News/2010/Riverbank+Filtration+Project+Completed.htm

World Class Innovation
The project is unique because Louisville Water is the first water utility in the world to combine a gravity tunnel with wells as a source for drinking water.

Louisville Water designed and constructed a mile-and-half-long tunnel in bedrock, 150 feet below the ground surface. The tunnel is parallel to the Ohio River at the company’s B.E. Payne Treatment Plant. Four wells were sunk to collect the ground water and send to the tunnel.  A pump station pulls the water from the tunnel and into the treatment plant.  Louisville Water can pump up to 70 million gallons of water a day from the aquifer.

Louisville Water began Riverbank Filtration in 1999 with a 15 million gallon per day test well. Extensive water quality research and testing occurred over the first several years of its operation to verify the water quality and the replenishment of the water table.  Based on the success, Louisville Water expanded the project to include four additional wells, a tunnel and pump station.  The tunnel minimizes the above-ground impact.  The wells are capped at the ground and only the pump station at the B.E. Payne Plant is visible above-ground.

A Green Supply
There are several advantages to Riverbank Filtration.  Because the water is cleaner, it requires less treatment.  The process eliminates taste and odor issues, provides an additional barrier for pathogen removal and creates a stable water temperature of around 55-degrees, resulting in fewer main breaks in the distribution system. 

Design and Construction
Construction began in March 2007 and was complete in the fall of 2010.  The $55 million dollar investment was funded through Louisville Water’s capital budget. Jordan Jones & Goulding provided engineering and design.  Mole Constructors, Inc. was awarded the bid for construction of the tunnel and pump station.

No groundwater monitoring well test results have been obtained from the Louisville Water Company for the wellhead protection area in Prospect around the Riverbank Filtration Project.  Shown here is the concrete cap of  collector well N0. 3. The bridge approach appears to pass 50 yards south of this well. See the layout site map below provided by Louisville Water Company.

The potential for groundwater contamination is increased by large shopping center parking lots and developments in the wellhead protection area as well as a KPDES permitted barge washing facility just across the river. Wellhead protection area signage has not been installed as depicted in the wellhead protection plan filed with the state.