More Information Compliments of
Mountain Watershed Association:
PO Box 408, Melcroft PA 15462 (724) 455-4200
mwa@mtwatershed.com
“Talking points for tonight’s meeting on the Curry Mine are attached. Some of it is more technical--- feel free to use only what you are comfortable stating. Please remember that if you are not able to attend,
you can also submit comments in writing for up to 30 days after the hearing. Here’s the address:
DEP Greensburg District Mining Office, Armbrust Building, RR #2, Box 603-C, Greensburg, PA, 15601. Address comments to Michael Gardener, and reference SMP # 26070106.
The environmental concerns are key in relation to the permitting process. DEP will not be swayed on the basis that the Youghiogheny is the PA River of the Year or that this mining will be done within 300 feet of the bike trail.
Talking Points on Amerikohl’s Proposed Curry Mine
The total bond that Amerikohl is required to post for this site is $239,594.13. The site is proposed to be 588.5 acres (with the mining area 279.9 acres of that 588.5); this works out to be 417.13 per acre for reclamation should the company abandon the site and forfeit the bond.
The NPDES permit (PA No. 0251305) will allow discharges from 7 sediment ponds and 5 treatment facilities; these will discharge into 5 UNT to the Youghiogheny River.
This site proposes to divert water out of the Morgan Run and Johnson Run watersheds (both are designated as High Quality Cold Water Fisheries) through the use of diversion ditches which will control the direction of surface water. However, the site is partially located in both the Morgan and Johnson Run watersheds, so any water that is diverted out of those watersheds is water that will no longer reach the streams. This is not an appropriate use of streams that are designated HQ-CWF’s.
Deforestation and lack of riparian buffers will contribute to deterioration in water quality in these streams.
Chestnut Ridge Trout Unlimited is attempting to remediate Morgan Run from mine drainage, and recently received a Growing Greener grant from the PA DEP to install a passive treatment system. Further degradation in a stream that CRTU is attempting to remediate using hundreds of thousands of dollars worth of taxpayer funds would be extremely counterproductive. Morgan Run is not currently reaching its HQ-CWF designation due to mining in the headwaters of the watershed; this is the area where CRTU is planning to construct a treatment system.
THERE IS NO REMINING TO TAKE PLACE ON THIS SITE. THE ONLY CURRENT AMD SOURCE IN MORGAN RUN IS THIS SITE IN THE HEADWATERS. Many people have recently said that the company will be reclaiming past damage; THIS IS SIMPLY NOT TRUE. THE ENTIRE PROPOSED CURRY SITE IS ON PREVIOUSLY UNMINED LAND.
Should this system of diversion ditches break down or become overwhelmed due to a high precipitation event, the potential exists for untreated water to be discharged into Morgan and Johnson Run.
This area could be home to many threatened or endangered species.
A PNDI search for Morgan Run showed:
16 potential plant conflicts
3 potential mammal conflicts (two of which may be the Allegheny Wood Rat and the Green Salamander)
2 potential herpetile conflicts
3 potential habitat conflicts, which may include limestone outcrops that could be home to the endangered Allegheny Wood Rat and Green Salamander)
3 potential geologic feature conflicts
This is a total of 27 potential conflicts; it remains unclear how the company intends to resolve these conflicts.
This project, due to the amount of traffic (20 tri-axle truckloads per day for 21 months) into and out of the site as well as the amount of disturbed area, has the potential to introduce many invasive species that could cause harm to the threatened or endangered species.
-invasive species thrive in areas that have recently been disturbed
-invasive species are often introduced to areas through roadways and by piggybacking on equipment
-because the proposed mine area is bordered by contiguous forest the danger of introduction of invasives is certainly a potential problem
-there is currently no protocol (i.e. plan to clean equipment before entrance to site) from the mining company to address these issues.
In the permit, section 8.4a says that all receiving streams are unnamed tributaries (UNT) to the Youghiogheny River, and are designated as warm water fisheries (wwf). However, the public notice states that the receiving streams COULD INCLUDE Morgan Run, Johnson Run and the Youghiogheny River. All are high quality cold water fisheries (HQ-CWF). What does ‘COULD INCLUDE’ mean?
This site is located in the immediate vicinity of a very significant recreational resource, the Youghiogheny River Trail. This trail draws numerous visitors to our area and is an important economic benefit (Ohiopyle State Park hosts 1.9 million visitors annually). Amerikohl, in Module 24 of the permit in which they attempt to justify operating within a high-quality watershed, states that the ‘operation represents important economic benefits to the area.’ What are these benefits? Do they outweigh the benefits provided to our area by tourism and recreation (and specifically the bike trail and adjacent Ohiopyle State Park)? Was a cost-benefit analysis performed?
A full overburden analysis should be completed prior to the issuance of this permit in order to ensure that no acidic discharges that may have detrimental impacts on water quality are created. Acidic overburden exists in this area and has contributed to numerous acidic discharges in the past. The promises of the company to ‘special handle’ acidic materials are not enough, especially considering that we already have 4,000 miles of streams that are impacted by abandoned mine drainage. *please emphasize this as the Fish and Boat Commission is asking for it as well and we should back them up!
Special protection watersheds include streams designated HQ. Alkaline addition is not to be considered in special protection watersheds where a permit would not be issued on its own without alkaline addition. Alkaline addition cannot justify or support permit issuance in a special protection watershed.”
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Other items I learn in doing some research is that right now the State park has 4 streams impacted with acidic run off from overburden (Ram Cat Run, Meadow Run, Cucumber and Jonathan Run), the permit will be zoned out of Dunbar Twp and the permit states that a forest buffer will be utilized (due to elevation and the coverage of the trees) so limited if any blast curtains will be used, that the mining will utilize the Camp Carmel road for truck traffic – this is the same road that is access through the state game lands and is used for emergency access in that section of the park.