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<br />• In September, 1990, ENSR Consulting was directed to conduct a °toxicity character- <br />, ization' study to identify the primary cause of the toxicity. This study considered pH <br />effects, volatile organic carbon, metals chelation, aeration, total dissolved solids <br />' (TDS) and ammonia. The lab determined high TDS (chlorides) as the primary cause <br />of the toxicity. However, a recent review shows no correlation between LCD values <br />and chloride or TDS levels. <br />WFU has taken the following measures to reduce toxicity of the effluent. <br />' • On-site aeration structures were installed for HZS removal before discharging the <br />effluent. <br />1 • A pilot test was conducted to identify a flocculent for removing high levels of oil and <br />' grease from the effluent. <br />• The main water source of the mine was changed from the high TDS(>5000 ppm) <br />' alluvial well water to a significantly lower TDS (500 ppm) surface lagoon. <br />• The raw water tank was thoroughly cleaned and disinfected to remove sludge built <br />' up over years. This sludge was found to contain significantly high levels (1000 <br />colonies/ml) of bacteria. <br />• An MSHA waiver was received to stop the use of Wendon Dustrol-10 surfactant in <br />the water spray at the longwall face. The surfactant has been found to be lethal to <br />' fish life at 500 ppm. <br />The WOCD also sent an effluent sample and prior toxicity reports to the EPA laboratory in Duluth, <br />Minnesota to investigate the cause of toxicity. WFU believes WOCD has not heard from EPA in this <br />regard. <br />On December 28, 1992, WOCD wrote to WFU asking either (i) to develop a control program which <br />eliminates the toxicity through treatment of the TDS or (ii) to perform a study which determines if <br />TDS is having a toxic effect on the stream and to develop a level of TDS at the discharge point at <br />which an instream impact is not expected. On March 29, 1993, WFU submitted a plan to use the <br />' Rapid Bioassessment Protocol III per EPA guidelines. Under this plan, WFU would test the extent <br />of impairment, if any, on the aquatic life in the White River due to the mine water discharge. It will <br />involve sampling and testing of micro-invertebrates. No fish will be collected since the U. S. Fish <br />1 <br />' 15 <br />1 <br />