Stop Surface Mining!
We ask that Alpha Natural Resources stop mountaintop removal mining on existing sites and not apply for future mountaintop removal permits. We are opposed to mountaintop removal mining because of the significant impacts that it has on our communities. Coal companies are literally destroying communities that have been here for generations, such as Lindytown, Edwight, and Paxville, as residents are bought out to make way for mountaintop removal mining. Families have been denied access to cemeteries where their ancestors are buried.
Mining blasts cause serious damage to homes, even outside the half-mile blasting radius within which residents are required to be notified of blasting plans. Blasting also releases significant amounts of dust; elevated levels of airborne, hazardous dust have been documented around surface mining operations. Blasting has also destroyed and/or contaminated drinking water. For example, in Prenter, WV, blasting from a mountaintop removal site likely opened up pathways underground for coal slurry that had previously been injected into an abandoned underground mine to migrate into peoples’ wells. This contamination of peoples’ drinking water with coal slurry led to severe health impacts, including brain tumors, kidney failure and liver failure.
By removing soil and vegetation, mountaintop removal leads to erosion and increased risk of flooding during severe rains. Sometimes flooding is also caused by failure of sediment control ponds that are meant to contain runoff from sites. An especially bad flood in Dorothy, WV wiped out homes and destroyed lives when a 12 ft sediment control ditch from a mine near the town failed; people described a 10 ft wall of water coming through the town.
Mountaintop removal mining has also led to serious surface water contamination. Valley fills often bury headwater streams. Downstream of valley fills, streams contain significantly higher levels of metals and other contaminants. For example, selenium – a toxin that is known to cause deformities in fish – is found at concentrations greater than the toxic threshold in more than 90% of streams impacted by mountaintop removal. State advisories are in effect for excessive human consumption of fish from these waters.
Partially due to the impacts of mountaintop removal mining, a 2010 study from West Virginia University found a statistically significant relationship between residence in a high coal mining area in Appalachia and increased human cancer mortality.
Save Coal River Mountain!
Shut Down the Brushy Fork Impoundment!
The report and the emergency evacuation plan
Report summary: there are 9 pillars that were designated by massey’s own consultants as having safety factors less than 1.5 in the long term analysis and are in need fo supplemental support. These pillars were never provided supplemental support according to my research, because Micheal karmis from virginia tech who has never sided against the industry in his engineering reports on mining was hired to produce a study saying that the pillars would not have an effect on the dam stability. He further went on to say that even if all the pillars were to fail at once, then there would be no effect on the dam stability in “worst case” scenario analysis. This did not address breakthrough into underground mines like we saw in Martin county.
OSMRE and dep have largely accept ed Karmis’s report and not gone deeper into addressing the issue of breakthrough potential due to pillar failure. OSMRE may have a report coming out soon on this, but blasting effects are not likely to be in it with respect to pillar stability.
In 2004 Paul McCombs hired an outside engineer because we were putting pressure on him about the dam. The guys name was Don East, I believe, and he owned an Engineering company in Colorado. Coal River Mountain Watch and Donnie Sams (UMWA) went on a site visit of the impoundment. Donnie asked McCombs if we could take a look at the pillars beneath the dam. McCombs stumpled with words and said the mine was flooded. That may have been when they decided to flood it because Don East at the same meeting said 9 pillars were weak. So, how did Don East know this? Did he inspect them in a flood of water?
Nearly all of the pillar stability analysis that was done assumes weathering is not likely to occur due to abnormally dry conditions in 1999 and certainly no later than 2001. DEP last went underground in 1999 according to the dam superindent at the DEP in oak Hill.
So we ask, is it flooded or is it dry in the eagle seam under the impoundment?
No More Slurry
We encourage Alpha to switch to dry processing technologies to process coal, in order to avoid additional coal slurry impoundments and underground injections. Underground injection of coal slurry has led to serious contamination of ground water in several communities in West Virginia, including Prenter and Rawl. In a legislatively mandated study, neither the WV Department of Environmental Protection nor the Department of Health and Human Resources could prove conclusively that underground injections of coal slurry were safe. Coal slurry impoundments are of concern because of the potential for catastrophic failure. The failure of the Buffalo Creek impoundment in Logan County in 1972 killed 125 people and released 132 million gallons of sludge. Massey has projected that a catastrophic failure of the Brushy Fork impoundment on Coal River Mountain would kill 1000
people.
Dry processing technology drastically reduces the volume of waste needing to be stored from coal processing and eliminates the production of liquid waste. This is a much safer technology that will protect communities from potential groundwater contamination from coal slurry. Alpha already makes use of this technology in its Wyoming mines. Dry processing has the advantage for the company of recovering more coal during processing.
Reducing Water Quality Impacts
We ask that you make committments to reducing the water quality impacts of mine sites.
1) We ask that you conduct a Cumulative Hydrologic Impact Assessment for each mine site. The assessment should include, at the very least, the watershed that drains the whole permit area, and each sub-watershed within that drains part of the permit area.
2) We ask that you respect the integrity of streams. This means not applying for variances to disturb land within 100 feet of a stream, re-assessing the need for existing valley fill applications and not started valley fills, and exploring excess spoil disposal alternatives such as better regrading or the use of existing valley fills.
3) We ask that you assess Massey’s existing water quality control plans with a committment to changing them to take a pro-active, preventative approach as opposed to the approach of waiting for problems to occur and then treating them. We ask that you commit to pro-actively fixing problems that do occur without requiring DEP intervention. We ask that control plans and monitoring programs take into account local conditions, such as geologic layers with high selenium or other potential pollutants.
4) We ask that hydrologic plans be written with particular attention to flooding. Scientific analyses of run-off and flooding conditions should be conducted for each permit. The effect vegetation has on controlling run-off should be factored into these analyses.
5) we ask that you work with the EPA on the new guidance on conductivity.
6) we ask that you work with the community by Distributing Environmental audit reports to the public, posting DMRs in a public domain, notifying citizens and regulators at the very instance of any sort of water pollution event including, but not limited to black water spills, and allowing for citizens inspections during any pollution event.
Reclamation Demands
One of Massey’s biggest problems was the poor reclamation work it did on mine sites. We ask that you recognize that the WVDEP’s bond release standards are not strict enough to allow the regeneration of native forests, and make five commitments to improve reclamation.
1) We ask that you not apply for contemporaneous reclamation variances.
2) We ask that you commit to making an honest effort to return land to approximate original contour. This means not applying for AOC variances or the mountaintop mining designation. It also means utilizing as much mine spoil for regrading as is technically possible, without factoring economics or expediency into determination of regrade slopes, bench widths, the amount of spoil used, erosion control plans, safety factors of regraded slopes, and restoring the details of the original ground slope. Regraded terrain should mirror the original terrain. Mining plans should be made with this in mind.
3) We ask that you commit to using the soil compaction and planting standards of the Forestry Reclamation Approach advocated by the Appalachian Regional Reforestation Initiative.
4) We ask that you commit to only using topsoil for reclamation. This means not requesting topsoil substitute variances or using “equal” or “better” material without a variance. This means removing and stockpiling all the topsoil off a site prior to mining, and using this topsoil for reclamation on that site.
5) We ask that you commit to planting only native vegetation, in natural distributions. Species that are native but not dominant should not be the primary species planted. Planting plans should be tailored to the local conditions of each site, so that the post-reclamation forest matches the pre-mining forest of the particular site.
6) We ask that you hire a professional certified forester to produce a forest management plan for each mine site.
7) We ask that a space be provided for a community voice in reclamation plans. Local communities should be given a say in determining post-mining land use and be granted free access to the land after reclamation. This includes hiring local people to do the reclamation work.
Save Blair Mountain!
