APPLICATION #1. SITE REGISTRATION APPLICATION FORM, CONSTRUCTION STORM WATER WV/NPDES GENERAL PERMIT (THREE ACRES OR GREATER).

 

Project Name: Longview Power-600-Megawatt Coal Fired Power Plant Construction-Phase 1.

 

Operator or Contractor– To Be Determined.

 

Acres Disturbed– 1.7, Rainfall Zone– Zone 1

 

Receiving Stream(s) – Crooked Run

 

Proposed Construction Schedule– Begin Jan 31, 2006 – August 2009.

 

Signed: Robert Place, 10/31/05.

 

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The above permit application was received on 11/2/05.    4 page.

 

Storm Water Pollution Prevent Plan, 10 pages of text, 91 pages of material plus 3 maps.
Received 11/2/05.

 

Ground Water Pollution Prevent Plan, 9 pages of text, 19 pages of material plus 1 map.

 

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APPLICATION #2.  "operation permit", 3/8/06.

 

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PRELIMINARY SUBSURFACE INVESTIGATION and GEOTECHNICAL EVALUATION,
Triad Engineering, Inc., Morgantown, WV, April 8, 2004.   Submitted to Division of Water & Waste Management, Permitting Section on May 3, 2006.  17 pages plus charts & graphs.

 

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1.  The Site Registration Application Form submitted on November 2, 2005 is nearly
two years old, and as such may not reflect accurately to the Public and the State as to the actual conditions for the proposed Power Plant.  Thus, this Application is not timely.

 

2.  The required "Operator or Contractor" name, address and phone number were provided only as "To Be Determined".  Therefore, the Application is incomplete and cannot stand.

 

3.  The "Acres Disturbed" is listed in item 5. at 1.7 acres, yet this cannot be the full extent of the construction area.  Thus, the Application is inaccurate and cannot stand.

 

4.  The "Rainfall Zone" for the proposed plant site is listed as Zone 1.  However,
a careful determination of the correct zone for this site, south of the Pennsylvania
stateline, is Zone 2.  Thus, the Application is inaccurate and cannot stand.

 

5.  The "Receiving Stream(s)" is listed as Crooked Run.  This is misleading and inaccurate, given that the actual receiving stream is the South Branch of Crooked Run, a.k.a. School Run, which is pristine and has a quality exceeding Crooked Run itself.

 

6.  The "Brief Description of Project" given in the Construction Permit Application is given as "Phase 1 of a multiphase construction.  Install a construction trailer and parking area".  This is inconsistent with the purpose of the Public Hearing now being held.  This Public Hearing is dealing with the overall Construction and Operation of the proposed Power Plant.  Therefore, the Application is incomplete and very misleading.  Thus, this Application is inaccurate and cannot stand.

 

7.  The "Proposed Construction Schedule" is given as "Begin Jan 31, 2006 - August 2009.  This
time period is not feasible, given that the start date cannot be met, and that an accurate start date is not know.  Therefore, this Application is inaccurate and cannot stand.

 

8.  The "zero discharge" nature of the proposed Power Plant is not realistic; and, "zero discharge" cannot be achieved as a practical matter with a large project involving thousands of gallons of water, multiple applications involving the water, and considerations as large holding ponds, water sprays for dust control, and multiple cooling towers involving water sprays and evaporation.  While it is possible to design systems that intend to have "zero discharge", such a condition cannot be sustained in the long term over years of continuous operation.  Hence, the "zero discharge" characterization cannot be accepted as a practical condition to prevail for the overall continuous operation of the Power Plant.

 

9.  This proposed Power Plant project has not been approved to disturb the historic Ft. Harrison location adjacent to Seece Lane, which includes an historic marker, trees, marshes and possible relics or other remains.  An adequate buffer zone is needed to provide for protection and preservation of this Ft. Harrison site, which dates from the 1780's.

 

10.  The proposed plant site includes a number of wetland areas, afforded protection by federal law. Any construction as implied in the Construction and Operation applications would interfere or destroy this wetlands.  Therefore, the permits should be withheld.

 

11.  Full investigations of rare and endangered species have not been completed for the proposed plant site and transmission corridor.  Until permits are granted by the U. S. Fish and Wildlife Service and approved by the WV Division of Natural Resources, the permits should be withheld to protect the full area that may possibly be disturbed.

 

August 21, 2006.