Warren Generating Station Permit: Comment from an anonymous citizen

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.

Respectfully submitted,

Anonymous Citizen 


  1. 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.
  2. Coal Ash: Hazardous to Human Health”, Physicians for Social Responsibility, United States Affiliate of International Physicians for the Prevention of Nuclear War.
  3. 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.
  4. “Addendum to Design Engineer’s Report, Water Quality Management Permit Amendment. Submitted June 20, 2014.
  5. 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:

Third-Party Report: Radical Detrimental Changes in Chautauqua Lake

Algal bloom, Chautauqua Lake 2019
Photo by Racine-Johnson Aquatic Ecologist from October 1, 2019. Cyanobacteria (blue green algae) or harmful algae blooms (HABs) dominated the south-east end of the south basin, including Burtis Bay, Elmhurst and Sunnyside

Dearth of aquatic plants in south basin leads to dangerous algal blooms, habitat loss

LAKEWOOD, NY Jan. 6, 2020 – A third-party’s 2019 fall survey of the habitat of Chautauqua Lake, a waterway that supports a rich economy based on sports fishing, recreation, vacation rentals and tourism, found the lake’s status had “skewed radically from the norm,” essentially creating two lakes, a vibrant, normal one north, and a barren, vulnerable one south.

A 158-page report from the independent and well-respected Racine-Johnson Aquatic Ecologists of Ithaca, NY states in unusually stark language for a scientific paper the changes observed. It documents how Chautauqua Lake exists in two extreme parts, with the south basin a barren lake floor where “data shows critical decline from a healthy sustainable littoral ecosystem;” and the north basin, where aquatic plants continue to grow well, buffering against dangerous algal blooms witnessed in the south basin last summer.

“Our late-summer/early-fall 2019 plant survey results came as a shock, and should alarm the stakeholders of Chautauqua Lake,” states the annual report prepared independently for the Chautauqua Lake Association. The report uses “macrophytes” as a scientific term for aquatic plants in the lake, where 27 species were found, none of them newly invasive.

“The outcomes we normally expect, after 18 years of consecutively collecting variable aquatic plant and invertebrate community data from Chautauqua Lake, skewed radically from the norm,” the report’s authors wrote. “The submersed aquatic plant growth in the north basin, north of Long Point, was normal and anticipated for a fall survey, generally good-to-excellent water clarity and a healthy growth of desirable macrophytes. South of Long Point, blooms of phytoplankton were obvious and did not dissipate during our survey.”

The survey, from Sept. 17 to Oct. 1, 2019 generally involved the rake-toss method of collecting plants to determine density and variety. The New York State Department of Environmental Conservation recently issued bid invitations for a three-year state project requiring use of the same certified approach, which involves gathering plants from the lakebed and analyzing their health and frequency.

What caused this radical change in the lake’s south basin? In spring of 2019, the herbicides 2,4-D and endothall were applied in near-shore areas south of Long Point. The report concludes these herbicides were highly effective, doing their job of killing nearly all plant life in those areas. But the report states that such removal is “detrimental to the health of the lake’s ecosystem.” The survey also found the herbicides killed well beyond a specific application zone, due to inevitable drift of the chemicals in the water column.

“The stakeholders of the lake may, or may not know, or recognize, what happened to Chautauqua Lake south of Long Point in 2019,” the report says. “The stakeholders that fish in the lake, who spend time at the shoreline or in a boat, have noticed that the summer months in the south basin, in 2019, were not the usual. However, this fall other stakeholders accepted the news reports, internet posts and a third-party report that the management of aquatic macrophytes by the application of aquatic herbicides, south of Long Point, on Chautauqua Lake in 2019, was a success and beneficial.”

“We agree, the application of the herbicides 2,4-D and endothall on May 15-17, 2019 was successful in removing macrophytes from large areas of the lake’s littoral zone (where plants grow). Conversely,
we do not agree that this almost total plant removal in those areas was beneficial, but rather it was detrimental to the health of the lake’s ecosystem.”

“The management decision to prohibit herbicide use north of Long Point in 2019 was astute and that decision must remain,” the report concludes.

The annual survey, according to the report, found few plants in the south basin, concluding that: “A decrease in macrophyte species diversity, richness and biomass has the potential of leading to a decline of a world-class, warm-water fishery dependent on the habitat that aquatic plants provide.”

“Since 2002, we have recorded for 17 years in the south-east end of Chautauqua Lake aquatic plants and macroinvertebrates as part of a vibrant lake ecosystem, while in the 18th year our data shows large areas in critical decline from a healthy sustainable littoral ecosystem,” the Racine-Johnson ecologists wrote.

In addition, since the herbicides were applied to water, its fluidity distributed them beyond the areas permitted for treatment, the report found. This finding, therefore, “clearly suggests the drift and concentration of 2,4-D was vast and basin-wide, likely contributing to the massive indiscriminate defoliation of the macrophytes in the south basin.”

“The wholesale loss of macrophytes may push the south basin toward a phytoplankton-dominated turbid state, void of many of the submersed plants, invertebrates and fish that have inhabited this
littoral zone historically,” the scientists continued. “While the south basin could recover quickly, it is likely to be a slow return to normal macrophyte growth with HABs [harmful algal blooms] currently having the advantage.”

According to the National Oceanic and Atmospheric Administration, harmful algal blooms, or HABs, occur when colonies of algae – simple plants that live in the sea and freshwater – grow out of control and produce toxic or harmful effects on people, fish, shellfish, marine mammals and birds. “The human illnesses caused by HABs, though rare, can be debilitating or even fatal,” the agency states.

Among the report’s additional conclusions:

  • The importance of having a robust healthy macrophyte community in the littoral zone of Chautauqua Lake is essential to the survival of this large, shallow lake. A decrease in macrophyte species diversity, richness and biomass [have] the potential of leading to a decline of a world class, warm water fishery dependent on the habitat that aquatic plants provide. Loss of macrophytes from the littoral zone in a large eutrophic shallow lake, like Chautauqua, will dramatically increase nutrient loading and shoreline erosion into the water column by allowing an increase in wind driven waves to whip up the bottom sediments and pound the shoreline. The loss of plant structure that provided refuge for the phytoplankton grazing zooplankton from planktivorous fish can lead to a zooplankton decline allowing phytoplankton and cyanobacteria to increase.
  • Therefore, conservation of these essential biological control agents is paramount in maintaining a healthy Chautauqua Lake. Protection from the wholesale elimination of macrophyte species from the littoral areas must be the top consideration in the long-term management of the lake. With the loss of macrophytes from large sections of the south basin, those areas will likely experience a decline of macroinvertebrates, the fishery and water clarity along with increased phytoplankton blooms and corresponding low oxygen levels. The management decision to prohibit herbicide use north of Long Point in 2019 was astute and that decision must remain. Prohibiting herbicide usage in crucial fish habitat specifically used for spawning and nursery is paramount as suggested at an earlier time in areas like Tom’s Point, Whitney Bay and Irwin’s Bay. The decision in 2020 for managers and stakeholders of Chautauqua Lake is how to improve the lake ecosystem south of Long Point while continuing protection to the north.

Racine-Johnson Aquatic Ecologists of Ithaca, NY, was formed by Robert Johnson upon his retirement as Cornell University’s Cornell Ponds Manager. Johnson has been monitoring aquatic plants and herbivores in Chautauqua Lake annually since 2002 under contract to the Chautauqua Lake Association as an independent monitor. Racine-Johnson also performs third-party consultant herbicide-monitoring for NYSDEC and other lake associations.

The Chautauqua Lake Association traces its beginnings to 1946 and its actual formation in 1953. The current focus is to perform environmentally sound plant-control practices, undertake scientific monitoring and relevant research, service the shoreline in promotion of maintaining healthy conditions, and promote educational efforts to enhance public understanding of lake association methods and lake needs. Since 1954, the CLA has sponsored lake improvement projects, has performed lake maintenance services, and has facilitated on-going scientific monitoring and research. The CLA is a charter member of New York State Federation of Lake Associations (NYSFOLA). For more information, visit http://chautauqualakeassociation.org/about-us/history/