Upper Monongahela River Association, Inc.
P.O. Box 519
Granville, WV 26534-0519

Monday 28 March 2005


Request for public hearing concerning mine water discharge permit applications:
(1) Dana Mining Company re-issuance of WVNPDES 1011715.
(2) Dana Mining Company Incidental Boundary Revision for Permit No. UO-251.
(3) Consolidation Coal Company re-issuance of WVNPDES 1003011.
(4) CORESCO re-issuance of WVNPDES 1002619.

(5) Request for disposition of CORESCO WV1017314 per hearing Granville VFD 6PM Wednesday 30 June 2004 (and apparently related permits WV1007394 and WV00952063).

Brenda Zickefoose
WV Dept. of Environmental Protection
105 South Railroad Street, Suite 301
Philippi WV 26416
304-457-3219 (fax 3440)

Dear Ms Zickefoose:

At this time, UMRA does not have enough information to reach any conclusions regarding the first three subject applications.

The fourth and fifth permits listed above are discussed at the end of this letter.

We do not oppose coal mining per se, and, our approach is to work with the coal operators to ensure that public interest is best served.

The mining and water treatment issues involved with these three applications need further public explanation.

We thus request that WVDEP hold a public hearing on these applications, so that DEP, Dana (Jimmy Laurita), and, Consol, might outline their plans, especially as they affect water quality in the Monongahela River watershed, and, mining effects on the surface, for water wells, homes, and streams above the Sewickley coal to be mined.

A major concern is the water quality legacy in the Monongahela River watershed that will follow completion of this mining. When the mining ends, what will be in place to ensure perpetual treatment of mine water filling this new mine and of course the old mines, before this water floods out of these mines and enters the Monongahela River?

The 2,000+ acres of Sewickley coal to be mined is located west of Morgantown, near Core and the Mason-Dixon Historical Park, an area of interest to the folks in the Dunkard Creek Watershed Association (DCWA).

Our UMRA Chief Technical Officer, Wally Venable, and I, attended the quarterly DCWA meeting held Saturday, 19 March, at the park. The meeting was chaired by Betty Wiley, President of DCWA, and she also is an UMRA founder and board member.

At the meeting, we learned that the Sewickley coal to be mined is being flooded by water rising up from the mined-out Pittsburgh seam below the Sewickley coal. This water must be removed before the Sewickley coal can be deep mined. Apparently the plan is to surface pipeline this water from the new mine to a borehole feeding into the old Pursglove mine. The water apparently then is to flow from Pursglove to Humphrey to Arkwright-Osage, all old closed mines, and is to travel further underground many miles east, through old abandoned mines, to the Consol treatment plant located near Booth. This plant discharges treated water into the Monongahela River near Flaggy Meadows, close to Edna and Six & Plum Marina and Campground, well south of Morgantown, into the pool of water behind the Hildebrand lock and dam.

In other words, this water that must be removed before the Sewickley can be mined, which one normally might expect to enter the Monongahela River north of Morgantown, via say Robinson Run or Dunkard Creek, now will enter the Monongahela River south of Morgantown, upstream of the intake for the Morgantown water treatment plant.

Now, this also leads to what is the plan for treating water once mining begins? Will the water treatment plan for active mining follow the above route? Or, will water be treated and discharged into streams nearby the mine, eg, Robinson Run and/or Dunkard Creek?

There are other questions of public interest. What is the market for the coal? The proposed Longview powerplant? Or, will the coal be trucked or otherwise delivered to other customers, eg, via Jimmy Laurita's Maidsville river terminal? What public roads will be used?

What surface infrastructure will compose the mine, ie, refuse piles, vent shafts, portals, ponds, roads, water treatment and discharge sites, etc?

What surface subsidence problems are expected, and, how will they be dealt with?

How long will the mine be operating? What is the closure plan?

We, UMRA, and others, may of course have further questions, as we learn more about what exactly is proposed for this mining endeavor.

Now, we move to the fourth and fifth permits cited in the subject line.

The fourth permit appears to apply to an existing and now operating strip mine, currently supplying coal to Mr. Laurita's Maidsville river terminal. It is also close to the site for the proposed Longview powerplant.

The fifth permit is in the same general area as the fourth permit. We have heard nothing since the 30 June 2004 hearing. What is the status of this permit?

We thus are seeing much permit activity relating to mine discharges into the Monongahela River within Monongalia County, from various entities owned, controlled, or working with Jimmy Laurita. We therefore ask that WVDEP and Jimmy Laurita explain how all this permitting activity and projects tie together, and, is designed to protect from further degradation the water quality in the Monongahela River and its tributaries.

Again, as we try to understand all of this permitting activity, we most likely will have further specific questions related to this request for a public hearing.



Donald C. Strimbeck, Secretary

304-599-7585 (fax 4131)

cc: Jimmy Laurita, Dana Mining Company, P. O. Box 1209, Morgantown WV 26507-1209.