PLEASE!! You only have a couple days to submit comments to DEP about Longview.

BEFORE OR ON THIS SATURDAY, SEPTEMBER 2^nd ! (Thanks to those who have already sent letters! We need more!!)

Please ask the WV Dept. of Environmental Protection to deny the Draft NPDES (discharge) permit for Longview. It’s hard to believe that a company submitted such rubbish, and even harder to believe that DEP approved it! We must require more of our regulatory agency. DEP is merely going through the motions, and we must call them on it. We must demand that the Department of Environmental Protection actually fulfills the “protection” part of its name! I urge you to pass this message along to anyone who may be interested.

The following is my letter to the DEP regarding the DRAFT water-discharge permit. I ask that YOU please send a letter as well. Write your own thoughts or feel free to plagiarize anything from the following letter, Since my letter is a bit long winded (a bit hurried and a bit rude), here are the main points I am trying to get across:

The application form, the fact sheet, and the draft permit appear to be for three different things. The application form states that 1.7 acres of land will be disturbed for a construction trailer and associated parking. The fact sheet is for stormwater runoff from the construction of a large power plant on 110 acres of land, and the draft permit (issued by the DEP) is for the construction and operation of a large power plant on 110 acres of land. Which is it?

The Operator or Contractor (Item 3) in the application is “to be determined.” So DEP does not know to whom it is granting the permit?

According to the application form, the Final Storm Water Management Plan has “yet to be determined based on design.”

So we have no operator and no design, yet we have a draft permit.

The Increase in Impervious Area (Item 16) in the application is not consistent with a 600-megawatt coal-fire power plant.

The gallons of water Longview says it needs in its permit application is one half to one third the amount of water needed, according to other documents and comments made by Longview elsewhere.

Speaking of water, Longview claims it will have zero discharge. That’s hard to believe.

Please send your comments to:

Director, Division of Water and Waste Management, DEP
ATTN: Michelle Brenner, Permitting Section
601 57TH St. SE
Charleston, WV 25304

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August 30, 2006

Director, Division of Water and Waste Management, DEP
ATTN: Michelle Brenner, Permitting Section
601 57TH St. SE
Charleston, WV 25304

Subject: NPDES Draft Permit No. WV0116238, Longview Power, LLC

Dear Ms. Brenner:

I have reviewed the draft NPDES permit and associated application for Longview Power, LLC, proposed to be built near Morgantown in Monongalia County, West Virginia, and I have the following comments:

1.) It would be nice if a copy of all future correspondence between Longview and the DEP could be placed in the Morgantown Public Library. Charleston is a 3-hour drive each way from here, and if Charleston is the only place the residents of Mon County can review Longview’s applications and the many pages associated with them, then that is an undue hardship on the people most affected by Longview. I respectfully request that you require Longview to make an extra copy of everything it sends to you, and I request that you send those copies along with copies of your correspondence with Longview to the Morgantown Public Library. The DEP’s Division of Air Quality did this for Longview’s air permits.

2.) There are significant inconsistencies between the information provided in the Site Registration Application Form, the associated “Fact Sheet,” and the actual Draft Permit. I find it difficult to believe that Longview filed an application with such errors, and I find it even more difficult to believe that our own DEP actually issued Longview a draft permit in the face of these glaring errors.

a.) The number of Acres to be Disturbed (Item 5 in the Application Form) is almost one tenth of the acreage in the Fact Sheet and the Draft Permit. What is being permitted? 1.7 acres or 110 acres?

b.) The description of the Project (Item 9 in the Application Form) is for installation of a trailer and parking area. The fact sheet is for construction of a 600-megawatt power station, and the actual draft permit is for the construction and operation of a 600-megawatt power plant! Which is it?

3.)   The information provided is woefully inadequate and incomplete. The Operator or Contractor (Item 3 in the application) has “yet to be determined.” Items 14 and 17 say that everything but the construction trailer and parking area have yet to be designed! How can the DEP grant a permit to someone they do not know for a project that has yet to be designed?

4.)   The Increase in Impervious Area (Item 16) in the application is not consistent with a 600-megawatt coal-fire power plant. The power plant and the land disturbed by it will result in an increase of far more that 480 square feet of impervious area and 5 cubic feet per second of discharge during peak storm events!

5.)   Item 10 of the Fact Sheets states that Longview will receive approximately 4,600 gallons per minute (gpm) of treated water from a plant in Pennsylvania, and that will fulfill Longview’s cooling needs. Everything else Longview has submitted states that treatment plant will produce 7,000 gpm (see, for example, the report entitled Use of Mine Pool Water for Power plant Cooling, prepared by Argonne National Laboratory for the US Department of Energy’s National Energy Technology Laboratory in September 2003). Longview has stated elsewhere that the water produced by the mine-pool treatment plant (approximately 7,000 gpm) will only be half of the water required by Longview, if it were built. Therefore, Longview states in the NPDES Fact Sheet that it will use approximately 4,600 gpm, but has stated elsewhere that is needs 15,000 gpm. This is a huge discrepancy. The true amount of water used by Longview must be clarified. The DEP must not allow Longview to pull numbers out of the air, as it is clearly doing.

6.)   No maps or plans were attached to the Application, Fact Sheet, and Draft Permit that was given to my neighbor when he drove all the way down to Charleston to get a copy of this permit and application. Were these crucial pieces of information even submitted to the DEP by Longview?

7.)   I find it difficult to believe that there will be NO water discharge. The statement that and extra water there is will be used for “dust suppression” is troubling. It sounds as if Longview will merely be land applying their water. I also don’t believe that Longview will send its untreated water back to PA!! What will that water be like after it has been through a cooling tower several times? In fact, I would like to see more details on how Longview plans to reuse water multiple times in its cooling fans. That water will be so mineralized after one or two passes, it is difficult to believe it would be usable. In addition, the water will be hot after one pass through. How can hot water be used for cooling?

8.)   There were no details on the water treatment plant proposed for the site; in fact it was barely mentioned in the application. There will be coal piles on site and other water runoff that must be treated, yet there is no discussion of this on-site treatment plant!

As with everything else Longview has submitted to date, this NPDES permit application is a bait and switch tactic. Longview has repeatedly submitted inaccurate and incomplete information to the State Regulatory Agencies. This company has said one thing and done another throughout the whole planning and attempted permitting process, and the DEP needs to call them on it now.

I hereby request that the DEP deny Longview’s NPDES permit because Longview clearly failed to provide information, ALL the information, in a complete and accurate manner.

Sincerely,

Paula J. Hunt