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<br /> <br /> • In September, 1990, ENSR Consulting was directed to conduct a 'toxicity <br />' characterization' study to identify the primary cause of the toxicity. This study <br /> considered pH effects, volatile organic carbon, metals chelation, aera- <br /> lion, total dissolved solids (TDS) and ammonia. The lab determined high TDS <br /> (chlorides) as the primary cause of the toxicity. However, a recent review shows <br /> no corelation between LCD values and chloride or TDS levels. <br />' <br /> WFU took the following measures to reduce toxicity of the effluent. <br />' • On-site aeration structures were installed for H2S removal before discharging the <br /> effluent. <br /> i <br />f <br />il <br /> • gh levels o <br />o <br />A pilot test was conducted to identify a flocculent for removing h <br /> and grease from the effluent. <br />' <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 Leaned 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 <br /> in the water spray at the longwall face. The surfactant has been found to be lethal <br />' to 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. WOCD never heard from EPA in this regard. <br />WOCD does not think it is now necessary since the mine has been passing the WET for the last ~'~ <br />' three years. A copy of the letter dated January 30, 1997 from WOCD is attached in Appendix H. <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 pi) to perform a study which determines <br />if TDS is having a toxic effect on the stream and to develop a level of TDS at the discharge point <br />' at which an instream impact is not expected. On March 29, 1993, WFU submitted a plan to use <br />the Rapid Bioassessment Protocol III per EPA guidelines. Under this plan, WFU would test the <br />extent of impairment, if any, on the aquatic life in the White River due to the mine water discharge. <br />' It will involve sampling and testing of micro-invertebrates. No fish will be collected since the U.S. <br />' 15 <br /> <br />