COLORADO SCHOOL OF MINES, DEPARTMENT OF ENVIRONMENTAL SCIENCE AND ENGINEERING

Hydrological Impacts of Mountaintop Removal in

Appalachia History and Solutions

Marc Petrequin

6/7/2012

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Abstract

Mountaintop removal/valley fill mining (MTR/VF) brings an array of environmental impacts at

every stage of the process, many of which directly and indirectly affect local hydrology and water

quality. Analysis of the practice in the region of its heaviest use, the Central Appalachian coalfields, has

revealed two primary causes of such degradation: valley fills and coal slurry impoundments. When

overburden from a mountaintop removal mine is dumped into the nearby valley, it significantly

increases the total dissolved solids (TDS) concentration, metal concentration, and pH of the water,

significantly degrading the water quality and stream activity and ultimately causing a loss of biodiversity

in local ecosystems. When coal from the mine site is processed and cleaned, the highly toxic slurry

byproduct must be stored in massive impoundments, where the risk of spilling into surface or

groundwater is a constant threat. Although the Surface Mining Control and Reclamation Act of 1977

(SMCRA) requires the reclamation of such disturbed land and water to reduce the impact of valley filling,

current technologies and a general misunderstanding of ecological processes make this impossible,

leaving most mitigation of the impact up to new federal and state litigation. Unfortunately, recent

changes to the Clean Water Act (CWA) have effectively sanctioned valley fills, requiring that any call for

stricter enforcement of environmental regulation on the matter begin with scientifically addressing such

discrepancies. In contrast, very little regulation has governed the construction and maintenance of

slurry impoundments since the first major spill incident, but a more recent incident of greater

magnitude has incited demand for new regulatory frameworks and technology to reduce the risk of

impact and the volume of slurry produced. This paper will review the history of MTR/VF, its process and

environmental impacts, and the steps that can be taken to mitigate such impacts.

Introduction

Mountaintop removal/valley fill mining (MTR/VF), or simply mountaintop mining, is among the

most controversial practices employed by the coal mining industry: while it is the fastest and most

efficient method of coal extraction today, it causes a wide array of environmental impacts in its wake,

particularly to the hydrology and water quality of the surrounding area and the inhabitants that depend

on it. With potable water quickly surpassing fossil fuels in rarity and value, any anthropogenic threats to

the resource deserve special consideration, particularly when such threats originate from a constantly

expanding practice. The impacts of these threats can best be observed and analyzed in the region

where the practice originated and has the potential to dominate the industry in the near future: the

coalfields of Central Appalachia.

The Central Appalachian coalfields cover roughly 12 million acres (48,000 square kilometers,

km2) in Kentucky, Ohio, Pennsylvania, Tennessee, Virginia, and West Virginia, and currently supply

roughly 19% of the nation’s annual coal production [1] [2] [3]. Coal surface mining in the area began in

the late 1940s with the most popular method being contour-strip mining up until 1970, when MTR/VF

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coal mining began on Bullpush Mountain in Fayette County, West Virginia. The practice expanded

predominantly in the 1990s, with the depletion of near-surface coal supplies and the development of

new large surface mining draglines, capable of moving over 100 cubic yards (yds3) of earth with every

scoop. Ironically enough, the 1990 amendments to the Clean Air Act ,calling for more stringent

emissions standards, actually increased the demand for West Virginia’s low-sulfur, high volatility coal,

inciting the practice of MTR/VF to expand further to the state’s southern counties [5].

Currently West Virginia contains an estimated 54 billion tons of coal reserves [6]. While the

state is still the largest producer of underground-mined coal in the nation, contributing about 70% of

total production, new technology and rising prices for natural gas and oil caused surface mining in West

Virginia to grow from 10% to nearly 33% of the state’s total coal production after 1990 [7] [6]. Between

1992 and 2002, local governments permitted 90,104 acres for MTR/VF in West Virginia, including 51,382

mining acres and 19,486 valley fill acres. Of the nine most heavily coal-producing counties in West

Virginia, 82.3% of the surface-mined coal currently comes from MTR/VF [5].

Since its inception the process has escalated from 44 permits covering 9,800 acres throughout

the 1980s to the granting of permits covering 12,540 acres in a nine-month period in 2002 [5]. From

1973 to 2000, Central Appalachian forest cover declined from 86.6% to 83.3% as a result of this

expansion [7]. As of 2010 the process has been used on over 470 mountains covering over 380,000

acres and nearly 2000 miles of streambeds as its practice continues to expand into Tennessee [8].

Including the effects of valley fills the process has impacted 1.4 million acres of land in the region, an

area roughly the size of Delaware [9].

Process

The process of MTR/VF can be broken down into six steps: clearing, blasting, digging, dumping,

processing, and reclaiming. In the first stage, the mining company removes layers of overburden on the

mountain: forests covering are clear-cut as machines scrape away topsoil, lumber, and undergrowth to

be stored for the reclamation process. Then, the mining company uses explosives to blast off the tops

of mountains to access the underlying coal deposits. These explosives use a combination of ammonium

nitrate (NH4NO3) and diesel fuel to remove as much as 800 to 1000 feet of the mountaintop. Coal

companies set of hundreds of these blasts daily, each one up to 100 times as powerful as the Oklahoma

City bombing [9]. The process uses nearly four million pounds of explosives every day in West Virginia

alone [8]. Because Appalachian coal usually exists in multi-layered geologically stratified seams, miners

repeat this blasting process over a dozen times on a single mountain [5].

After blasting, coal and debris are sifted through using a dragline, while overburden is collected

and either stored in backstacks or (more often) dumped into surrounding valleys, creating valley fill [7].

Depending on the local topography, a single valley fill can be over 1,000 feet wide, over a mile long, and

contain as much 250 million yds3 of overburden, burying any intermittent and ephemeral streams below

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[3]. Surface runoff on the mine is typically directed towards these valley fills, percolating through the fill

material and into constructed channels that lead to treatment basins used to settle solid particles,

precipitate metals, or regulate pH [1].

The collected coal is then transported to a processing plant for washing to reduce impurities,

such as clay, non-carbonaceous rock, and heavy metals. This leftover coal sludge, or “slurry,” is stored in

open impoundments, sometimes made from the valley fills created during the process [10]. Finally,

once the mining area has been exhausted of all coal reserves, the mining company reclaims the site,

typically by spreading the displaced overburden and spraying the area with grass seed [5].

Impacts of Valley Fill

Sulfate

The valley fill process is integral to all forms of surface mining in the steep-sloped areas of the

Appalachians, and even underground mining requires valley fill to create the necessary surface area for

support. This is especially true for MTR/VF mining, as the volume of fill material is typically significantly

greater than that of the excavated overburden [11]. The detrimental effects on the water quality of

valley streams include increased total dissolved solids (TDS), increased pH, and increased metal

concentration in the water and sediment. Dissolved solids typically include sulfate, calcium,

bicarbonate, and magnesium from pyrite (FeS2), calcite (CaCO3), and dolomite (CaMgCO3) in the

overburden exposed to water and oxygen. Autotrophic bacteria catalyze the oxidation of pyrite to form

sulfuric acid (Equation 1), a characteristic of acid mine drainage; in the presence of calcite and dolomite,

the acidity can be neutralized (Equations 2, 3) [1]. This increase in sulfate can exacerbate nutrient

pollution of the water by increasing nitrogen and phosphorous availability through internal

eutrophication, altering the phosphorus cycle of aquatic systems and causing exponential algae growth.

Elevated sulfate levels can also lead to an increase in the microbial production of hydrogen sulfide (H2S),

a toxin for many aquatic plants and organisms. Because this sulfate pollution originates from valley fills,

it persists long after the mining activities cease [13].

Equation 1: 4FeS2 + 15O2 + 14H2O 4Fe(OH)3 + 8SO42- + 16H+

Equation 2: 2CaCO3 + 2H+ 2Ca2+ + 2HCO3-

Equation 3: 2CaMgCO3 + 2H+ 2Ca2+ + 2Mg2+ + 2HCO3-

Conductivity

Other ions from water-soluble compounds in the overburden include potassium, sodium,

chlorine, and selenium, all of which contribute towards increased conductivity of the water [1]. Some of

these ions, as well as aluminum, manganese, and zinc, are released from the sulfuric acid weathering

the parent material (see Figure 1) [7]. The concentration of all such metals increases downstream of

valley fills from mountaintop mining, which can disrupt the water and ion balance in stream biota as

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well as an increase in water conductivity (see Equation 4). Conductivity of a dissolved ion is a product of

the ion’s molar concentration (millimoles per liter, mmol/L), the absolute value of its charge

(milliequivalents per millimole, meq/mmol), and its specific equivalent conductance (λ) in micro-

Siemens per square centimeeter per millieuivalents (μS/cm2/meq); the overall water conductivity is the

sum of the respective conductivities of the ions within. The greater concentration and charge of sulfate,

calcium, magnesium, and bicarbonate in stream water typically makes them the dominant species in

determining total conductivity [1].

Studies have proven conductivity of stream water is indirectly related to the macroinvertebrate

richness of the water, particularly mayfly populations [15]. According to a 2009 study by the U.S.

Environmental Protection Agency (EPA), over 63% of streams located in central Appalachian coalfields

were “impaired” by high levels of heavy metals and toxins [14].

Equation 4: Conductivity [SO42−] = Molar Conc. (mmol/L) × 2 meq/mmol × 80 μS/cm2/meq

Selenium

Of all these heavy metals, selenium (Se) presents the greatest threat to public and

environmental health. Selenium is a toxic metal, highly concentrated in coal, that becomes more

soluble at the higher pH levels created from the valley fill runoff [7]. When selenium bioaccumulates,

especially through streambed algae in ponds and reservoirs with high retention, it quickly saturates local

Figure 1: Storm water quality from valley fill streams in West Virginia in June 2001 [15]

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aquatic food webs, causing increased deformities and death in local fish populations and reduced

hatching in bird populations [1] [12]. A recent survey of 78 MTR/VF streams found that 73 had

exceeded the 2.0 micrograms of selenium per liter of water (μg Se/L) threshold for toxic

bioaccumulation, threatening any species that feed on fish in the area, including humans [13].

Stream Sediment

The overall increase in TDS in the water from MTR/VF increases the levels of stream sediment in

both suspended and bed load. Increased TDS is also a result of the deforestation during the mining

process, as such loss of vegetation leads to considerable erosion and an increase in peak discharge

during rainy periods [5] [11]. This increased sedimentation increases turbidity while decreasing

dissolved oxygen in the water, endangering countless aquatic macroinvertebrates and the larger species

that feed on them [15] [16]. A heavier bed load also fills in gravel spaces in the streambed, destroying

deep pool habitats that many biota rely on for spawning during the summer months [5]. Ultimately

excessive accumulation of overburden can lead to complete burial and loss of stream habitats, cutting

off the nutrient and organic matter of healthy headwater streams and further depreciating the size and

biodiversity of downstream aquatic communities [1] [5]. Such stream loss can occur over relatively brief

periods: between 1985 and 1989 for example, roughly 533 kilometers (km) of streams in Kentucky were

buried by valley fills, of which 57% were perennial and the remainder intermittent [4]. One should note

that in most Appalachian watersheds, headwater streams contribute up to 70% of the mean annual

water volume in second-order streams and 55% of the volume in higher-order rivers [17].

Other Direct Impacts

Stream loss can also occur from the removal of geologic layers and perched aquifers during the

blasting process [1]. Deeper aquifers can also be cracked by the blasting, allowing oil, gas, and sediment

to infiltrate and pollute the well water therein. At other times the well water runs out of the cracked

aquifer, forcing those relying on the well to drill another to avoid further industrial impoundments [18].

The loss of vegetation from MTR/VF can also create storm runoff issues for local residents: in 2001

flooding destroyed over 500 West Virginia homes near MTR/VF sites [4] [9].

From 1992 to 2002 the EPA approved MTR/VF permits that resulted in the loss of 1,944 km of

headwater streams to valley fills in Tennessee, Kentucky, Virginia, and West Virginia, almost three times

the length of the Potomac River. In 2001 the EPA designated 633 miles of the Kentucky River Basin as

unsafe for any kind of human use [18]. The Agency’s Programmatic Environmental Impact Statement

(PEIS) in 2002 subsequently projected that mine footprint and stream losses would double over 2002

levels by 2012 [1]. This damage to Appalachian streams has continued at an average rate of 120 miles

per year [14]. This rate is expected to accelerate as MTR/VF sites become larger, with some mine sites

reaching 12.5 km2 and some valley fills reaching more than 10,000 ft in length [19].

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Slurry Impoundments

An equally egregious affront to Appalachian aquatic ecosystems by MTR/VF mining is the

construction of slurry impoundments. As mentioned earlier, after coal is mined from the overburden, it

is washed in a chemical mixture to reduce impurities. Of the chemicals commonly used in this mixture,

19 are known carcinogens and 24 are linked to lung and heart damage. These chemicals combine with

the clay, non-carbonaceous rock, and heavy metals in the coal to form a thick sludge known as slurry

[10]. Every year, roughly 350-400 million tons of coal go through this processing, producing between

70-90 million tons of the slurry byproduct. This slurry is discharged into an exterior impoundment

consisting of a basin and an embankment, where it is constantly monitored to prevent spills. The largest

impoundment in the nation, the Brushy Fork impoundment in West Virginia, is 900 feet high with a

capacity of 8.168 billion gallons [5].

Although slurry impoundments are a byproduct of all coal mining, they are of particular concern

in areas of MTR/VF mining. Flash floods from vegetation loss in the vicinity of a slurry impoundment can

easily cause the dangerous sludge to spill downstream. Nearby blasting during the mining can cause

fractures in the impoundment that allow sludge to seep into the groundwater. Some of these

impoundments, including one owned by Massy subsidiary Marfolk Coal Company in Raleigh County,

West Virginia, sit on top of abandoned underground mines, further increasing the risk of groundwater

contamination [5]. While spills from such impoundments are rare, even minor spills or groundwater

leaks can cause dangerous consequences to nearby water quality. A 2004 study of 15 wells within 2

miles of Sprouse Creek Slurry Impoundment in West Virginia found well water often contained black

particles and yielded mineral concentrations in excess of drinking water standards [20].

The two most extreme cases of impoundment breaches occurred in Logan County, West

Virginia, and Martin County, Kentucky. On February 26, 1972, four days after a federal mine inspector

declared it structurally satisfactory, Pittston Coal Company’s slurry impoundment #3 in Logan County

burst, releasing 132 million gallons of slurry into Buffalo Creek Hollow, killing 125 people, injuring

another 1,121, and destroying 507 houses [5]. Nearly 30 years later, on October 11, 2000, the bottom of

Massey Energy’s Big Branch impoundment in Martin County broke into an abandoned underground

mine below, releasing roughly 306 million gallons of slurry into two tributaries of the Tug Fork River,

Coldwater Fork and Wolf Creek. The spill, roughly 30 times larger than that of the Exxon Valdez disaster,

killed all aquatic life in both tributaries and poisoned the water supply for nearly 27,000 residents [5]

[18].

During this period, the use of slurry impoundments has continued to spread throughout Central

Appalachia. West Virginia alone currently contains over 110 billion gallons of coal slurry in 126 different

impoundments [10]. Since the Buffalo Creek disaster the state has witnessed 32 impoundment spills, 20

of which occurred from 2000 to 2004 [5]. As of 2009, there were 88 sludge impoundments in Kentucky,

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20 of which are ranked as having a high risk of breaching by the Kentucky Environmental Quality

Commission [18].

Solutions to Valley Fill Impacts

Reclamation

Two primary statutes govern the practice of MTR/VF mining: the Surface Mining Control and

Reclamation Act of 1977 (SMCRA, 25 U.S.C. § 1201) and the Clean Water Act of 1972 (CWA, 33 U.S.C §

1252). The SMCRA requires mining companies to return excess spoil at the impacted site to its

Approximate Original Contour (AOC) and ensure that the quality of water leaving the site complies with

CWA standards without additional treatment [2] [14]. Due to a lack of clear definition of AOC, the

increased volume and instability of blasted overburden, a lack of knowledge regarding the ecological

functions of Appalachian streams (beyond the hydrologic functions), and a lack of overall enforcement,

effective stream reclamation from MTR/VF is currently impossible [1] [2] [3]. According to a 2011 EPA

report, former streams buried or contaminated by valley fill simply cannot be functionally restored, and

new streams created on former mine sites cannot effectively replace them [1] [14]. High conductivities

and concentrations of sulfate and trace metals persist in the streamflow of headwaters long after mining

activities cease, and existing mitigation approaches fail to reduce their export. When Emily Bernhardt

and Margaret Palmer at the Department of Biology of Duke University in North Carolina developed a

database on stream and river restoration in the U.S., they failed to find a single case out of 38,000

projects from 2002-2005 in which stream creation, as proposed by current MTR/VF mitigation plans,

adequately recreated either the hydrologic or the ecologic function of the original stream (see Figure 2)

[2].

New Regulation

Mitigating the impacts of valley fills lies in newer and stronger regulation of the practice. Under

Section 402 of the CWA, discharge of a pollutant into surface waters of the U.S. is prohibited without a

permit issued by the Army Corps of Engineers (ACOE). Under Section 404, however, the Corps may issue

a permit if the permittee agrees to avoid and minimize stream impacts (to the extent practicable) and

mitigate any unavoidable loss of stream functions by restoring or preserving other waters [8]. Until

2002 this exception applied exclusively to the discharge of dredged or “fill material” and specifically

excluded activities with the purpose of waste disposal, including valley fills [22]. In May 2002, however,

the Bush Administration passed a regulation that removed regulatory language that excluded “waste”

discharges from Section 404 and redefined “fill material” to mean material placed in waters to replace

portions of water with dry land or change the depth [23].

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Although the practice of valley filling from mountaintop removal had faced minor legal

interference in the past, it is now effectively sanctioned by Section 404 of the CWA, under the shared

authority of the ACOE and the EPA [22]. Moreover, recent review of MTR/VF practices has revealed

considerable leeway within the Section 404 requirement that the permittee mitigate unavoidable loss of

stream functions: as analysis has shown, the permittee is typically unable to recreate the original

stream function, but may not realize this until years after the mining operations cease. And even with

these loopholes, a considerable lack of CWA enforcement persists in MTR/VF mining practices in Central

Appalachia. A 2003 EPA review found 150 valley fill violations in West Virginia, where coal companies

had been illegally dumping into valleys without proper CWA permits [5].

Any attempt to mitigate valley fill impacts legally must first address these inadequacies. In May

2005 Rep. Frank Pallone (D-NJ) introduced the Clean Water Protection Act (H.R. 2719) to the 109th

Congress, which would redefine “fill material” to exclude surface mining waste. In March 2009 Sen.

Benjamin Cardin (D-MD) introduced the Appalachia Restoration Act (S. 696) to the 111th Congress, which

would redefine “fill material” to exclude any pollutant discharged into surface water “primarily to

dispose of waste” [14]. Either of these bills would effectively reverse the 2002 loophole and prevent the

Figure 2: (A) An unmined Central Appalachian landscape, (B) Wind River mine 20 years after

reclamation, (C) A typical Central Appalachian stream, and (D) a created stream in Nicholas

County, WV, 15 years after reclamation [2].

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granting of MTR/VF permits under Section 404 of the CWA. As yet neither bill has been signed into law,

nor has the Obama Administration taken a stance on this issue [23].

If any such bill is passed, it must also contain provisions that call for greater scrutiny in both the

Corps’ issuance of valley fill permits and the EPA’s enforcement therein. Under the CWA the EPA still

has the power to veto a permit granted by the Corps under Section 404 if the activity would have “an

unacceptable adverse effect” on water quality [22]. The permanent loss of stream functions in the

MTR/VF process, as the recent EPA study has revealed, could easily constitute grounds for such a veto.

Any further regulation should also call for more lucid definitions of AOC designed for runoff of fill

material with greater understanding of both ecological and hydrological stream functions. Ideally this

will help ensure future valley fills are constructed to prevent transport and deposition of TDS offsite and

achieve short- and long-term stability [11].

Solutions to Surry Impoundment Impacts

Regulation

While the environmental and social threats posed by slurry impoundments contribute

significantly to the impact of MTR/VF mining, their construction and maintenance has been the subject

of considerably less litigation and regulation than valley fills. Shortly after the Buffalo Creek Disaster the

Mining Safety and Health Administration (MSHA) developed standards for slurry impoundments and

promulgated regulations to address their design and monitoring under 30 C.F.R. §§ 77.214, 77.215, and

77.216. Essentially these regulations only require that any slurry impoundment have an elevation of at

least 5 feet above the upstream toe of the structure and a storage volume of at least 20 acre-feet (one

acre-foot is the volume of one surface acre to the depth of one foot, about 43,560 cubic feet), and that

any plans for the design, construction, and maintenance of coal impoundments must be prepared and

submitted to MSHA for approval prior to construction. Although individual states may impose stricter

regulations (West Virginia requires a minimum height of 25 feet and a storage capacity of at least 15

acre-feet), these have been the only federal requirements for slurry impoundments for the last 30 years

[5] [21].

In response to the Martin County impoundment spill, the National Research Council (NRC)

appointed the Committee on Coal Waste Impoundments to examine engineering practices and

standards currently applied to slurry impoundments, evaluate the accuracy of mine maps in relation to

impoundment planning, and evaluate alternative technologies that could reduce the amount of coal

waste generated. Published in a 2002 report, the Committee’s recommendations included that any

further regulation to slurry impoundment design, particularly in the Appalachian Coalfields, allow MSHA

and the Office of Surface Mining (OSM) to have clear authority of review over design, that both MSHA

and OSM develop new guidelines for site evaluation and the design and construction of impound basins,

and that both administrations consider requiring additional continuous monitoring of established

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impoundments. To reduce slurry generation, the Committee recommended gradually reusing coal slurry

as a source of fine coal as newer dewatering technologies become available. Typically, if an

impoundment contains at least 1 million tons of slurry, a recovery rate of at least 30% of a marketable

fine coal could provide a considerable economic incentive [21].

Technology

In addition to the reuse of slurry as a coal source, several methods have been recently

developed to reduce or eliminate the amount of slurry generated during coal refinement, any of which

could be applied to reduce the potential impact of slurry impoundments. In a dry press filter, for

example, a closed loop of water washes the coal, and the waste slurry is pressed into dry filter cakes to

be stored appropriately in lined landfills. The entire process typically costs an additional 50 cents to 1

dollar per ton of coal processed. Several companies in West Virginia have already begun employing this

technique. Various dry coal cleaning technologies, using electrostatic or magnetic separation or air and

motion, require no water at all, and can separate coal from mineral matter at a lower energy cost,

smaller plant size, and no required monitoring of effluent [24].

Conclusion

Although the general consensus of scientists and engineers in the energy field accepts the

practice of MTR/VF mining as inevitable in the national energy portfolio, its impacts to the hydrology of

Central Appalachia cannot be ignored, and the lack of effective land reclamation and governing

regulation has left considerable room for improvement. Valley fill from the clearing of overburden

directly causes loss of headwater streams and contributes towards pollution of downstream waters,

severely impacting local aquatic ecosystems long after the nearby mountaintop mine closes. While an

effective method of reclamation currently remains impossible, proper environmental regulation can

mitigate the impact posed, provided significant changes are made to Section 404 of the Clean Water Act

and the EPA and ACOE undertake greater responsibility in enforcing it.

Slurry impoundments, meanwhile, pose significant potential threats to nearby surface and

groundwater systems and residential communities, yet relatively little regulations exist to uphold any

standard of safety in their design and maintenance. Only after a second major spill has the need for

regulatory review become nationally recognized, and a comprehensive study by the National Research

Council has produced a comprehensive framework on which newer regulation and technology can be

applied to reduce this risk.

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