Editors note: this comment was submitted in October, 2019, when the Warren Generating Station proposed a Draft Renewal Permit. It is an example for others who plan to comment on any future permit modification, and because it contains well-documented concerns that must be addressed in any future permit.
The Pennsylvania Department of Environmental Protection withdrew the permit application, and as of this date, the permit application process remains ongoing. Commenters have requested a public meeting in Warren for the re-drafted permit with Meadville DEP personnel. A notification of the re-draft will be announced in the Pennsylvania Bulletin, after which the public will have only has 14 days to comment.
Mr. Justin C. Dickey, P.E.
Environmental Engineer Manager
Clean Water Program, Permits Chief
Department of Environmental Protection
Northwest Regional Office
230 Chestnut Street
Meadville, PA 16335
RE: Public Comment Period Extension, NPDES Permit No. PA0005, Warren Generating Station, Conewango Township, Warren County, Allegheny River Watershed 16-B
Dear Mr. Dickey:
As a resident of Warren County and a citizen of the Commonwealth of Pennsylvania, I write to you regarding the Draft Renewal Permit for Warren Generating Station Power Plant located in Conewango Township, Warren County. As you are aware, a portion of the facility has been closed and steam units have been deactivated. The combustion turbine (CT) continues to be operated and will be transferred to Warren Power LLC, who will submit a permit amendment to address this change.
Per the Fact Sheet in the Draft Permit, wastewater consisting of treated ash disposal site leachate will be discharged into the Allegheny River in State Water Plan Watershed Plan 16-B, which is classified for warm water fishes, aquatic life, water supply and recreation.
This leachate is classified under 40 CFR 423 as: “combustion residual leachate. Leachate from landfills or surface impoundments containing combustion residuals…composed of liquid, including any suspended or dissolved constituents in the liquid, that has percolated through waste or other materials placed in a landfill or that passes through the surface impoundments containment structure.”
These collected screenings, slurries…and other solids shall be…disposed of in compliance with the Solid Waste Management Act, 25 Pa. Code (multiple chapters), federal regulation 40 CFR Part 257, The Clean Streams Law and the Federal Clean Water Act and the Endangered Species Act.
In the Fact Sheet on Receiving Waters, an Impaired Assessment is listed for this waterway as caused by Mercury and Pathogens, with “source unknown.” Is this Assessment from a state water quality assessment report as approved by EPA and on what date? I note that your Data Source on this sheet lists samplings 15– 20 years ago and flow calculations up to 30 years ago, with some years of no data.
Under Development of Effluent Limitations (as defined as Best Professional Judgment BPJ), the permittee lists planned monitoring of chloride and nickel. Under Endangered Mussel Species Concerns, the permittee discusses required sampling of ammonia-nitrogen, chloride and nickel. They also state:
“The Department has limited data to support its determination that a properly constructed, operated and maintained industrial wastewater treatment facility of this size is expected to produce an effluent that would be protective of all the uses of the receiving stream including threatened and endangered mussels.”
“Limited data” is a bit of an understatement as no “chloride sampling was completed at the time of this …application and “the nickel concentration exceeds the USFW criteria.” It concludes with: “considering the lack of data for Chloride and the exceedance of the nickel criteria, the Department will establish quarterly effluent monitoring … to develop a dataset to further evaluate potential impacts.”
So, for the few pollutants the permittee addresses, the data provided in the permit is poor or nonexistent. As for all the other components found in coal ash leachate: arsenic, lead, mercury, cadmium, chromium, selenium, aluminum, antimony, barium, beryllium, boron, chorine, cobalt, manganese, molybdenum, thallium, vanadium and zinc, none of these are addressed in any form by the permittee. According to Physicians for Social Responsibility (Reference 1), these toxic metals have cancer and nervous system impacts, can cause heart damage, lung disease respiratory distress, kidney disease…birth defects, impaired bone growth in children…cognitive deficits, developmental delays.
“In short, coal ash toxics have the potential to injure all of the major organ systems, damage physical health and development, and even contribute to mortality”. (Reference 1)
This paper also describes pathways to exposure:
“leaching or dissolving into water, contaminating groundwater or surface waters like rivers…Some are consumed when people eat fish that have been contaminated by coal-ash exposed water or sediments. This poses a serious threat to the life forms that live in and eat from these waters. The pathways by which the water and fish can become contaminated include: runoff and erosion…direct discharge of coal ash runoff due to heavy precipitation or flooding and direct discharge of ash pond water and landfill leachate through pipes from waste units. …. Selenium fish impacts persisted for 11 years…Adverse impacts to birds feeding on contaminated fish persist …decades.” (Reference 1)
Wet surface impoundments consistently show higher risks than landfills. (Reference 2)
Now that the reader of the Draft Permit has reviewed what the Permittee plans to monitor and what are not mentioned at all, let’s look at the Treatment Facility Summary page. Treatment type is listed as “Chemical Precipitation” in “Ash disposal ponds” (original permit issued in 1975) and defined as:
Leachate storage pond, pump station, leachate treatment consisting of 2-stage pH adjustment and aeration, settling, sludge thickening, filter press, sludge hopper, and “ancillary equipment.” (Original permit issued in 2003).
Even as a non-scientist, this outdated method of water treatment seems to me to be wholly inadequate to protect any life form. This was the method used by another NPDES Permittee slightly upriver from this site until all the mussels were killed and they found themselves in federal court being ordered to upgrade to a mechanical vapor recompression unit.(4) Due to the close to $2 million cost just to lease this equipment, that plant chose to close, leaving 2.64 miles of the Allegheny River “Impaired” as defined by the state water quality assessment report (2014, 2016) and as defined by EPA. (5) Or as the US Fish and Wildlife published study (2015) (3) described that section, “a dead zone”.
I happen to live on that “dead zone” section of the Allegheny River in Warren. This is our part of the river. All of our lives we have lived in close contact with the (former) wildlife that depend on the River: fish, waterfowl, blue herons, muskrats, otter. We previously entered into the River to fish, swim, canoe.. Now we cannot enter our section of the River again, nor can our children and grandchildren.
I happen to live on that “dead zone” section of the Allegheny River in Warren. This is our part of the river. All of our lives we have lived in close contact with the (former) wildlife that depend on the River: fish, waterfowl, blue herons, muskrats, otter. We previously entered into the River to fish, swim, canoe.. Now we cannot enter our section of the River again, nor can our children and grandchildren. There is nothing alive in the 2+ miles where we live. There are not even rabbits in the adjoining fields or peepers along the water’s edge.
The 2.64 miles ends just about at Mead Island, which is a little downstream from this power plant location. Since the River continues to be Impaired from this plant downstream (with mercury), let’s not create another dead zone. Nor poison the wildlife that remains there. Physicians for Social Responsibility concludes that:
Coal ash is dangerously toxic and poses a threat to human health. It’s wet storage should be phased out.” (2)
These are the facts of our lives here. Think about them when you make decisions in Meadville and Harrisburg and consider the oath you took on entering public service.
- “Coal Ash: The Toxic Threat to Our Health and Environment – A Report from Physicians for Social Responsibility and Earthjustice”. Gottlieb, Barbara with Gilbert, Steven, PhD, DABT, and Evans, Lisa Gollin Evans.
- “Coal Ash: Hazardous to Human Health”, Physicians for Social Responsibility, United States Affiliate of International Physicians for the Prevention of Nuclear War.
- “Effects of High Salinity Wastewater Discharges on Unionid Mussels in the Allegheny River, Pennsylvania. Patnode, K.A.*, Hittle, Elizabeth, Anderson, Robert M., Zimmerman, Lora, Fulton, John W. 2015.
- “Addendum to Design Engineer’s Report, Water Quality Management Permit Amendment. Submitted June 20, 2014.
- Pittsburgh Post-Gazette, 12/29/2014.
Readers are encouraged to contact the following officials at PA DEP Northwest Regional Office with questions or concerns, or to request a public hearing in Warren County: