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January 4, 2016
Mr. Bharat R. Patel, P.E.
Regional Clean Water Program Manager
Pennsylvania Department of Environmental Protection
2 Public Square
Wilkes-Barre, PA 18701-1915
|RE:||DRAFT NPDES PERMIT NO. PA0275727 / INVENERGY’S PROPOSED LACKAWANNA ENERGY CENTER, LLC (LEC)|
Madam or Sir:
Trout Unlimited is the nation’s largest coldwater conservation organization, with more than 13,000 members in Pennsylvania focused on protecting, conserving and restoring North America’s trout populations and their watersheds. In Lackawanna County, we have more than 250 members working to fulfill our mission by protecting headwater stream habitat, reconnecting streams where barriers impede fish passage, restoring streams impaired by land use activities and educating and engaging the next generation of anglers and conservationists.
Twenty one miles of the Lackawanna River is designated Class A, Wild Brown Trout, special regulations, with a water quality designation of “High Quality””Cold Water”. It is not stocked in that 21 Miles because it has Naturally reproducing wild Brown Trout. The River has been listed in the latest edition of the “100 Best Trout Streams in America. The River played Host to the 2015 National Trout Unlimited Convention and has a high economic value for the people and communities in it’s watershed. Grassy Island Creek the location of LEC’s waste water is a tributary of the Lackawanna River.
Our organizations’ boards of directors believe the LEC’s treated cooling process water, from the first day of the plant’s operation, should be pre-treated on site and then discharged to the Lackawanna River Basin Sewer Authority (LRBSA) for additional treatment. We are concerned that the temperature of this water, its pH, and dissolved solids could be injurious to the creek, the river and the wildlife that find habitat in and around these bodies of water.
With monitoring and open dialogue following the plant’s startup, we believe eventual direct discharge to the creek could be feasible but prefer LRBSA treatment be available at the plant’s start-up and at all times during the plant’s operation in the event of a malfunction or other unexpected event.
Addressing only the effects upon the watershed and not having the expertise to discuss other factors of EFC’s permit, our scientist have raised the following questionable factors in the permit application;
- The Pennsylvania Fish and Boat Commission in 2012 approved a report generated by their science team in 2010 that recommended to the DEP to have the water quality designation for the Lackawanna River upstream from the Greenridge Street Bridge in Scranton to downstream of Carbondale upgraded to “High Quality”. According to Secretary Quigley’s office at DEP, any rivers or streams recommended by the F&BC for upgrade will be treated as such in the period between submission and final approval by DEP. This portion of the Lackawanna has a High Quality designation and as such requires that DEP protect the quality of the water which includes temperatures in a cold water fishery.
Baseline data has been established by LVTU for the month of July (heat of Summer and low water) shows an average water temperature between 58 and 62 degrees with spikes in extended period of high ambient temperatures of 64 degrees. Studies show that there can be a 7 degree temperature increase from the proposed discharge point of LEC’s property downstream on Grassy Island Creek through the open area near Breaker Street. Proposed maximum releases of 70 degree Temperature at the discharge point with the 7 degree temperature differential would have water entering a 62 degree Lackawanna at 77 degrees from Grassy Island Creek. 77 degrees is fatal to Brown Trout. Keep in mind also maximum releases from LEC (CFS) could be double the volume CFS of the Lackawanna during periods of extremely low water.
- The maximum daily loading (mg/l) of several of the heavy metals and the suspended solids appear extremely high. The aforementioned study by F&BC shows the River in the area from Section 7 and above having an average PH level of 7.4 with the area near grassy Island Creek having a PH level of 7.2. DEP proposed allowed maximum of a PH level of 9.0 is 110 times more alkaline than the Lackawanna River. This will degrade the river water quality and have a negative impact on not only the fish population but other aquatic species and aquatic vegetation and aquatic insect life.
- According to the permit, Section III.C.3 LEC is allowed to use residual and Municipal waste in the cooling towers. Residual waste include but not limited to, wastewater from Oil and Gas wells, food processing waste, landfill leachate and waste from Hydraulic fracking . Municipal Waste includes but not limited to, septage and liquid sewage sludge from treatment plants. Why is prior approval not required?
- First and foremost LVTU recommends that all waste water, not including stormwater run-off, be run by pipe directly to a Municipal Waste Treatment facility capable of handling the increased capacity.
These additional recommendations come only after open and deliberate and meaningful negotiations of maximums can be agreed upon by parties in standing.
- The reduction of maximum allowable daily loading of heavy metals and suspended solids along with a maximum PH level of 7.5
- Maximum Temperature releases during June July and August be held at 62 degrees with water never entering into the Lackawanna at higher temperatures than recorded in a real time data recording system located above the confluence of both streams.
- LVTU recommends that there be as little earth disturbance in the area where run-off of Erosion and sediment can affect the water quality of Grassy Island Creek.
- Recommended that real time data loggers be installed by LEC with real-time access available to the public, at LEC’s discharge point on Grassy Island Creek (above and below) and at the confluence of both GIC and the Lackawanna (above and below).
- Recommended that a riparian buffer be established the entire length of GIC and have it made a Greenway and placed into conservancy.
This in its entirety are the concerns and recommendations of the Lackawanna Valley Trout Unlimited Board of Directors at this time. LVTU neither endorses of nor is it opposed to the granting of this permit or the Invenergy project.
Charles Charlesworth Immediate Past President LVTU
Adam Nidoh President LVTU