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GFF OF SWACE MG
RECLAMATEGNAND WQRCEWNT
132? Virginia Strainliast
Charle?ien, West Virginia 2530}

APR ?31} 2315

   

Rmdy Huf?nan, Secretary

West Virginia  of
Bum.  mental.? . Pmtectim

6.0.1 57* Sheet, '53

Charleston, West Virginia 25304

Dear  Hu?nain:

As you knew, the of?ce of Smfface  Reelamati'on and Enfomeinent- (OSMRE) approved
major changes in the" State?s alternative.  system mainly    provided for
the  of the Council to. oversee the State?s Special Reclamation-.Fimd.. At the
?int: ejf approval and   still feels that the  ofthje. State?s altetnative
building system is largely dependent  the Advisory Connc?,  that body was  to 
 the ieft?ec?ve. ef?cient and  stable. operation. Of'thei Special. Reclamation  -

Currently, your "agency; in cooperation. With the  Council, is  to issue a
contract to an   to evaluate  brig?term  conditionofthie 

   the Speci a1. Reclamation  Treatn'ent Trust- Fund-_. My purpose
for wxi?ng is to identify some of the. potential  that  "that I do not ?nd. have been
fu?y'ana?lyze? in fun}: e-i'isk with the am "i 'a1 report? proces? s. -

I hate previoust  these  with  of yam sta?? and ihe Advisory
Council. Givm the pte?c?iibus ?nancial: situatien  ef'thie State?s coal  ?nd
themselves in today,-_ it would be  for. the. West Virginia  of-?Environmeaial
Protec?en (WVDEP) and the AdVisnry Code to  the risk of failure of seine effhe. sites
with unusual reelmnatien liabilities that may be more. costly? than re?ected by  forfeinnes
to date.

Some include, but are not limited to:

SeVeral companies within the State haveor are proposing to   
systems. The cost to install one-of- theSe Systems  range from few million'dollars. to
$50 million. The annual   costs of ?iese sele?nimntrea?nt
systems can run several mum dollar's depending 9n the amount of'w'ater tube treated.
As you knew, many oftheSe  Eminent systems are in the experimental stage,
and their effectiveness is Still not proven. -

Randy Hu?nan . 2

0 There is a pipeline and reverse osmosis plant in Mannington, WeSt'Virginia, which was
completed in March 2013, and treats pro-treated. water from ?ve (5) active and inactive
undergroiind  The reverse osmosis plant retrieves chlorides. and total dissolved
solids ?rm the mine water. The plant, which can treat up. to: 3,500 gallons per minute,
together with the pipeline cost approximately $200" million to. and has an
operating and  cost" of several million per year. 

I recently released two reports (Fainnont and the North Branch of the Potomac
mine pools) indicating hydrologic connections aniong underground mines that requires
extensive pimping and treatment to prevent pollution to major river systems. Other such
Systems exist adthin.West Virginia that have not been studied. The constructiOn and
annual maintenance costs of?aese treatment facilities are largely to-re'gulators
at this point.

a Stream loss, due to subsidence by underground mining, is another isSue that has received
little attention in the past dining actuarial reviews.- HoweVer, the cost" to restore a stream
and to replace the aquatic life therein once water less has occurred can be expensive. and.
dif?cult to achieve.

When projecting future liabilities. about the Special Reclamation Fund in the past?, actuarial {inns
have relied heavin on historic bend forfeittne. reclamation data. Although they exist, We do not
believe." the issues described above have been factored into their asmptions or'proje'ctions. This
is primarily. because seine. are relativer new issues or- they  not ?l?lly  as. being
potential. liabilities in the past. Therefore, I recommend that you  these issues to the
Advisory Council and roguest that they be presented to the actuarial ?rm for consideration
during the hpcoining actuarial study.

We also ask that WVDEP and the. Advisory Council pursue concepts that would build die type of
?nancial assurance pro gram? that'would truly address the patentially perpetual nature. of many of
the? water pollution discharges. It is evident that a varying fee on: current production will not
sustain the. funds necessary for treatment systems for the. decades or.  

Thank you for giving this matter your  attention. Please notify us if we can provide
you or the Advisory Council any assistance with this 'e??ort.

Sincerely,

  
 



  

Roger-W. Calhoun, Director
Charleston Field Of?ce

cc: Patty Hickman
Michael Sheehan