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II.C.Ii.d.1 Whole Effluent Testing. BME (fortneriy Western Fuels-Utah [WFUll started the whole effluent <br />• toxicity (WET) testing program beginning in the fourth quarter of 1989. The mine water effluent was found <br />toxic to the test species. Accelerated testing was conducted but the toxicity to the species continued. <br />In a meeting with Colorado Water Quality Control Division (WOCD) staff on January 31, 1992, the mine <br />staff reiterated the biomonitoring events, and various measures taken to identify the toxicants and to reduce <br />the toxicity. The following steps were taken to identify potential toxicants. <br />• In the early stages of WET testing, fhe undisassociated H,S in the effluent was deemed to be a <br />potential toxicant. However, a WET testing done by ENSR Consulting in June 1990 after removing <br />HzS by aeration still showed toxicity. This result indicated that some other factor(s) also contributed to <br />the toxicity. <br />• In September 1990, ENSR Consulting was directed to conduct a 'toxicity characterization" study to <br />identify the primary cause of the toxicity. This study considered pH effects, volatile organic carbon, <br />metals chelation, aeration, total dissolved solids (fDS) and ammonia. The lab determined high TDS <br />(chlorides) as the primary cause of the toxicity. However, a review showed no correlation between <br />LCD values and chloride or TDS levels. See Figure II.G33. <br />The following measures were taken to reduce toxicity of the effluent <br />• On-site aeration structures were installed for H,S removal before discharging the effluent. <br />• A pilot test was conducted to identify a flocculent for removing high levels of oil and grease from the <br />effluent. <br />• The main water source of the mine was changed from the high TDS(>5000 ppm) alluvial well water to a <br />significantly lower TDS (500 ppm) surface lagoon. <br />• The raw water tank was thoroughly cleaned and disinfected to remove sludge built up over years. This <br />sludge was found to contain significantly high levels (1000 colonies/ml) of bacteria. <br />• An MSHA waiver was received to stop the use of Wendon Dustrol-10 surfactant in the water spray at <br />the longwall face. The surfactant has been found lethal to fish I'de at 500 ppm. <br />• <br />Permit Renewal #3 (Rev. I/00) II.C-87 <br />