This is a response to WaDOE concerning the new NPDES permit written by WaDOE for Centralia Mining Company. The CRC has several concerns about the seemingly loose interpretation of the Washington State water quality rules.

January 14, 1998

Water Quality Permit Coordinator


Department of Ecology


Southwest Region Office


P.O. Box 47775


Olympia, WA 98504-7775

Gentlemen,

Thank you for the opportunity to comment on the December 31st revision of the draft renewal of NPDES permit WA0037338 for Centralia Mining Company. This letter and the attachment have been reviewed by the Chehalis River Council Board of Trustees.

We will restate that the Chehalis River Council is extremely interested in the continued protection of the waters of Washington State and in particular the waters of the Chehalis Watershed.

After a review of the 1992 Permit and Fact Sheet and the revised 1997 Draft Permit and Fact Sheet, as provided by Wa. DOE, we still have questions and areas of grave concern. These are spelled out in the attachment. Some of the areas of concern are:

  1. There is conflicting information in the Permit and Fact sheet. It is difficult to reconcile what is actually planned for the permit.
  2. We were pleased to see that turbidity was added, but after reviewing the Permit and the Fact sheet, we are not sure what the intent is.
  3. We are concerned, based on the information you provided in the permit, that there are no limits on temperature or turbidity.
  4. We continue to be concerned about the reduced monitoring frequency.

We feel in the interest of maintaining the health of the watershed that it is imperative that permittee demonstrates weekly that the permit requirements are met. We do not agree that a monthly sampling frequency meets the requirements of a NPDES major facility, with 600 workers spread over 3 shifts, 7 days a week, that processes 5,000,000 tons annually, on a 14,450 acre site and was last inspected 3 years and 8 months ago (April 1994).

Thank you again for the opportunity to comment,

Dave Palmer

Chairman

Attachment: Chehalis River Council NPDES questions

cc:

January 14, 1998: Chehalis River Council Question List

NPDES Permit Application, Centralia Mining Company

May 28, 1992 Permit, page 3 of 18, Treatment System Operating Plan and Solid Waste Control Plan

These are not a part of the 1997 document. Aren't they a valid topic of concern for a major NPDES permit?

January 14, 1998: The CRC restates this concern. How does DOE know that a Operating Plan and Solid Waste Control Plan is not needed? Is there another document somewhere which describes the applicants plans for the mine area and somehow eliminates public knowledge of changes in operation?

1997 Draft Permit, page 4 of 15, Discharge Limitation

Please explain why there is difference, in 1997, between required tests at different outfalls.

January 14, 1998: The CRC is still concerned that there is a distinction between tests for outfalls 5, 6, 8 and all the other outfalls. On page 5 of this document Iron is included as a parameter, but it is not included on page 4. The CRC is concerned that Oxygen measurements for outfalls 5, 6, and 8 have been left out. Further the CRC does not know, from these documents, that outfalls 5, 6 and 8 operate or will operate any differently than outfalls 1, 2, 3, 4 and 9. Are there restrictions in this permit, someplace, that will guarantee or prevent changes in use of outfalls 5, 6 and 8? If there are no restrictions then these outfalls need to be tested in the same manner as all other outfalls.

1997 Draft Permit, page 5 of 15, All measurements

January 14, 1998: The CRC is still very much concerned that the testing frequency for a major NPDES permit holder has been changed to monthly. A statement in the DOE material mentions something about good performance resulting in reduced frequency. The CRC believes the previous sampling frequency influenced good performance.

Why have the 1992 permit's weekly intervals all been changed to monthly in the December 1997 draft permit? If the objective of the NPDES permit is to protect the waters of the state of Washington, doesn't this reduced sampling cycle puts these waters at risk?

1997 Draft Permit, page 5 of 15.

January 14, 1998: Sample point LNHC cannot be found on the map or elsewhere in the documents.

1997 Draft Permit, page 5 of 15, Turbidity

January 14, 1998: Turbidity as a parameter is now restored to the December 1997 draft permit. Turbidity is a key factor in the assessment of water quality. Yet, in the fact sheet, page 8, it states the limits have been removed. Has turbidity been reinstated as a parameter? What is the limitation? Why doesn't turbidity appear on page 4 of the Draft Permit? Turbidity appeared under limitations in the 1992 permit.

1997 Draft Permit, page 4 and 5 of 15

January 14, 1998: What is the proposed limitation on temperature? The CRC is concerned that temperature is omitted from the parameters on page 4. A temperature limitation appeared in the 1992 permit. What temperature readings are acceptable on this proposed draft permit? (See question 13)

1997 Draft Permit, page 4

January 14, 1998: Early detection of oil and petroleum products seems desirable. Why has the daily inspection for sheen (1992 permit) been eliminated? Waiting for monthly tests seems to be very loose protection of the waters of the state of Washington.

Fact Sheet, page 2, Background Information

January 14, 1998: The Centralia Coal Mine is described a NPDES major facility, 600 workers, and around the clock operation 7 days a week. According to DOE information the mine processes 5,000,000 tons annually, on a 14,450 acre site and was last inspected 3 years and 8 months ago, back in April of 1994.

Doesn't this scope of activity demand more than once a month monitoring? An explanation of why this major facility is reduced to monthly testing would be appreciated.

Fact Sheet, page 4, History, Discharge Outfalls

January 14, 1998: The map supplied subsequent to the first draft document doesn't illustrate or indicate where active mining is taking place, what is inactive or what is being reclaimed. Somewhere in the permit or fact sheet a statement is made about a new pond, but even this is not apparent on the newest map.

This lack of active, inactive, new or reclaimed area information makes it very difficult for a review process.

Fact Sheet, page 6, Technology Based Effluent Limitations

January 14, 1998: The 1997 draft permit allows a Daily Maximum of 40 mg/L for TSS.

Since no daily average is specified, doesn't this in effect raise the average to 40 mg/L? Have the standards changed since the 1992 Permit? The 1992 had a specific Daily Average of 20 mg/L. The draft 1997 permit would allow a daily average of 40 mg/L. How does DOE justify this loosening of the 1992 permit requirements?

Fact Sheet, page 6 Surface Water Quality Criteria Limits (for turbidity)

January 14, 1998: The statement "no outfall discharges directly to Hanaford Creek, all discharge to wetlands, or insignificant ditches" appears in conflict with earlier descriptions of the property.

On the same page, under "Description of Receiving Water' it is stated that "The facility discharges to Big Hanaford Creek and its tributaries ..... which are designated as "Class A" receiving waters in the vicinity of the outfalls. "

At the bottom of page 6 DOE states that "limits for turbidity have been eliminated for this permit as appropriate since no outfall discharges directly to Hanaford Creek. How does DOE explain this very obvious inconsistent statement?

Fact Sheet, page 8, Monitoring Requirements

January 14, 1998: The first paragraph states: "Monitoring, recording, and reporting are required ... to verify that the treatment process is functioning correctly and the effluent limitations are being achieved"

The third paragraph on the fact sheet states: "Monitoring frequency for Oufalls (sic) 001, 003 ... and 008 has been reduced from weekly to monthly, partially for good performance in meaningful parameters".

Please explain this apparent conflict between the requirements for monitoring and the greatly relaxed sampling frequency allowed in this draft permit.

Fact Sheet, page 8, Turbidity and Temperature

January 14, 1998: The third paragraph, under Monitoring Requirements, states "monitor for turbidity, temperature and dissolved oxygen in the main stem of the creeks where these parameters are significant"

Please explain that statement since earlier on this page, turbidity has been removed.

Also, while Temperature is listed on the Draft Permit, and is part of the Proposed Permit Limitations (Narrative Criteria) on page 6 of the fact sheet, temperature is removed in the Comparison of Effluent Limits table on page 8 of the fact sheet. How can this inconsistency be explained?

1992 Permit and 1992 Fact Sheet, Monitoring Frequency

January 14, 1998: Both of the mentioned documents included a monitoring trigger for exceptional storm events.

Why isn't this monitoring requirements trigger included in the applicants 1997 Draft Permit or 1997 Fact Sheet?

Is DOE, by omitting storm event triggers from the 1997 permit, planning to allow any storm event runoff, no matter how harmful, without public notice, measurement and evaluation?


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