NOTE: The WV DEP Water and Waste Management Division will hold a Public
Hearing on Tuesday, August 22 at the Basic Sciences Auditorium of the WVU
Medical Center, 6 pm.
This is an important hearing, given that the Applications from Longview have
problems that should not be allowed to stand up for approval.
Please attend and speak if you can support any of the following or other
objections to the Applications. One Application is for the Construction
and the other for Operation of the power plant. But, both are being
considered together even though the first is substantially incomplete.
See below...............
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Longview Power, LLC, 10040 Great Plain Avenue, Needham, MA 02492
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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STATEMENTS OF DUANE NICHOLS REGARDING
THE "CONSTRUCTION PERMIT APPLICATION"
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.
