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The Obama administration is pressuring mining companies to work with regulators to deal with the most extreme problems from coal mining while allowing MTR to continue. The administration appears to be acting under the belief that reclamation is possible after MTR. Volumes of scientific evidence do not support the administration’s position.

In the case of valley fills, for example, only the EPA has ecosystem-wide responsibility through the Clean Water Act which governs what may be dumped in streams and waterways. But the agency’s power is circumscribed; it shares authority with the U.S. Army Corps of Engineers, which actually grants the dumping permits and has taken a much more sympathetic view of the practice. The Interior Department, meanwhile, oversees mountaintop projects via another law, the Surface Mining Control and Reclamation Act.

Nevertheless, the White House is betting that mountaintop mining can be managed and the damage ultimately repaired. But the science indicates that such an incremental approach may never be effective. Mountaintop removal does damage on both vast and microscopic scales, from hydrological changes over hundreds of square miles to effects on the life cycles of the tiniest stream microbes. Overseeing the repair of such damage is beyond the capabilities of any government agency; the most serious impacts — to streams — may be all but impossible to fix.

Margaret Palmer, a biology professor at the University of Maryland, was part of a team of scientists that compiled a comprehensive database of 37,000 U.S. river and stream restoration projects. She found no record of any mining-related stream-building project that could be called ecologically successful.

“Can you create these streams de novo, from scratch? There’s no evidence,” says Palmer, who testified on behalf of West Virginia environmental groups in a suit faulting the Army Corps of Engineers’ stream management. “Over thousands of years, I think you could do it. You have to have erosion of the land, get the hydrology back. I’m a restoration ecologist — I hope it can be done. But given how much damage they’ve done, right now I don’t think so.”

Sedimentary rock forms over thousands to millions of years of geologic time by the slow accumulation of of lose sediment which is gradually compacted and dewatered by compression from the weight of burial. Coal seams were once boggy areas that very slowly filled with decayed organic matter. Wet organic matter matter is a chemical trap for selenium, arsenic and sulfur which are mobile in an aerobic environment but are immobile in the anaerobic conditions where wet organic matter accumulates. The process of lithification sequesters not only the carbon as coal but the selenium, arsenic and sulfur in accessory minerals in the rock.

The slow natural weathering rates in Appalachia gently release small, safe amounts of CO2, selenium, arsenic and sulfur to the environment. The low porosity and permeability of the natural rock keeps most weathering reactions that slowly release toxic elements in the subsoil zone. One of the key weathering reactions that generates sulfuric acid and toxic elements is the weathering of pyrite – FeS2 – iron sulfide.

Four chemical reactions describe pyrite weathering but they can be summarized as one reaction.

4 FeS2 + 15 O2 + 14 H2O -> 4 Fe(OH)3 ¯ + 8 H2SO4
Pyrite + Oxygen + Water -> Ferrihydrite + Sulfuric Acid

This reaction shows how pyrite oxidation generates acid mine drainage. What is less understood by decision makers is that sulfate generation may cause secondary reactions that leach toxic elements from mine wastes even when the mine drainage is not acidic. Moreover, Selenium is a minor element, in the same position on the periodic table as sulfur, which behaves much like sulfur in the environment. Selenium levels in stream water downstream from MTR “valley fill” commonly exceed EPA water quality limits.

SELENIUM RESULTS FROM THE EIS ON MOUNTAINTOP COAL MINING AND OTHER STUDIES
Selenium in Stream Water and Bottom Sediments

Se was analyzed in 213 stream-water samples as part of the EIS; 66 samples, all collected downstream from valley fills, exceeded the aquatic wildlife standard of 5 µg/L. The median concentration of Se detected at EIS sites downstream from valley fills was 11.7 µg/L while the median concentration for un-mined sites was below the detection limit of 3 µg/L. Subsequent sampling by the West Virginia Department of Environmental Protection (WVDEP) detected Se in 126 of 909 stream-water samples and resulted in nine streams being placed on West Virginia’s 2002 303(d) list; four are in the Coal River Basin (Beech Creek, Left Fork Beech Creek, Rockhouse Creek, and Buffalo Fork) where 121 of the 126 Se detections occurred, four are in the Guyandotte River Basin, and one is in the Gualey River Basin. During July 2002 through June 2003 all 11 samples from Left Fork Beech Creek exceeded the 5 µg/L Se aquatic-wildlife standard; all four samples collected during February through June 2002 exceeded 35 µg/L (WVDEP). Se detections were most common during low flow; 95 of 126 detections were associated with total suspended solids concentrations (TSS) of 5 milligrams per liter (mg/L) or less; the highest seven Se concentrations were associated with TSS < 3 mg/L. In contrast, when TSS exceeded 50 mg/L (indicating overland runoff) there were only three associated detections of Se.

Photo by John McQuaid: Contaminated Outflow from a Holding Pond where a Stream Used to Flow By FishOutofWater

MTR valley fills are a consistent and persistent cause of Clean Water Act standards violations. There is no practical way to remediate the effects of MTR on water quality. Stripped mountains and filled valleys are, on a human scale, a permanent source of contaminants to surface, ground and drinking water.

MTR is clearly causing systemic biological degradation according to the US EPA PDF.

We explored a causal link between MTM and biological degradation, and our data support the type of logical argument summarized by Beyers (1998) for
establishing causal connections. Fore (2003) modified Beyers’ 10 criteria and demonstrated causal links between human disturbance and biological condition in mid-Atlantic streams. The 10 criteria are: 1) strength, 2) consistency, 3) specificity, 4) temporality, 5) dose response, 6) plausibility, 7) experimental evidence, 8) analogy, 9) coherence, and 10) exposure. Eight of the 10 criteria were relevant for constructing a causal inference argument with our bioassessment data.

We excluded specificity (because the bioassessment tools respond to many sources of degradation) and exposure (because we did not evaluate exposure indicators in affected organisms). Our data met 6 of the remaining 8 relevant criteria:

1. Ninety-three percent of the mined streams and none of the unmined streams were impaired using the preferred genus-level GLIMPSS, indicating the strength of the association.

1. The relationship between MTM and biological impairment has been confirmed by other investigators working in the Central Appalachians of West Virginia and Kentucky, indicating consistency.

1. Because our unmined sites were not impaired and were selected to be typical of least disturbed reference sites, these sites are representative of premining conditions in the watershed. We think it is reasonable to conclude that mining disturbance preceded the observed biological change (temporality).

1. Biological condition degraded in response to increasing mining disturbance, as measured by mining-related water-quality parameters, indicating dose response.

Mountaintop Removal Mining poisons water, literally turns the land into a waste land and devastates Appalachian communities. Coal mining conservatively costs five times more for Appalachians than it earns when human health costs are considered.

Coal mining costs Appalachians five times more in early deaths as the industry provides to the region in jobs, taxes and other economic benefits, according to a groundbreaking new study co-authored by West Virginia University researcher Michael Hendryx.

Coal-mining economies are not strong economies, [Coalfield communities] are weaker than the rest of the state, weaker than the rest of the region, and weaker than the rest of the nation.

Writing with co-author Melissa Ahern of Washington State University, Hendryx reports that the coal industry generates a little more than $8 billion a year in economic benefits for the Appalachian region.

But, Hendryx and Ahern put the value of premature deaths attributable to the mining industry across the Appalachian coalfields at — by one of their most conservative estimates — $42 billion.

Those cost estimates do not include the future costs of global warming. Coal is not cheap power. Coal only seems inexpensive because the largest costs are passed on to others and future generations. Wind power is far less expensive than coal when the total costs are considered.

The Obama administration should ban MTR immediately for consistently violating the Clean Water Act. It cannot be engineered to be safe. It is not good for the economy. Reclamation after MTR is impossible. Comprise is impossible. MTR must be banned.