East Lynn Lake Coal Leases
Final Land Use Analysis and Final Environmental Impact Statement
On June 11, 2012, the Bureau of Land Management released the Final Land Use Analysis (LUA) and Environmental Impact Statement (EIS) for East Lynn Lake Coal Leases in Wayne Conty, West Virginia. The protest period ended on July 9, 2012. Below are links related to the release.
The Bureau of Land Management (BLM) has received two applications to lease a total of 13,089.55 acres of federal coal near East Lynn Lake in Wayne County, West Virginia. Under the BLM regulations for competitive leasing (43 CFR 3425.1), BLM will prepare the East Lynn Lake Coal Lease Land Use Analysis /Environmental Impact Statement (LUA/EIS) prior to holding a competitive federal coal lease sale. Both applicplicants are proposing to mine the coal by underground mining methods from existing mines they currently operate on adjacent private land. The lands being considered for lease border East Lynn Lake on portions of both its north and south shores, but no mining would occur directly beneath the lake itself.
The lease-by-application process was initiated by Argus Energy LLC (Argus), and Rockspring Development, Inc. (Rockspring). However, if a decision is made to proceed with the leasing process, it is a competitive process open to all qualified bidders. The LUA/EIS process includes several planning and analysis steps involving information gathering, public involvement, agency coordination, impact analysis, and making a decision regarding the leases (see the LUA/EIS Process and Estimated Schedule).
A slide presentation is included on this website to provide an overview of the project. This presentation was also shown at the scoping meetings.
Proposed Action – The Proposed Action for this LUA/EIS is to decide to lease 13,089.55 acres of federal coal for underground mining from existing, adjoining operating facilities. The LUA/EIS process will describe a Proposed Action, a No Action alternative, and one or more additional alternatives that will be developed through the scoping process and initial analysis.
Reasonably Foreseeable Development Scenario – The Reasonably Foreseeable Development Scenario (RFDS) describes the development expected if the Proposed Action is approved. In this case, the RFDS will include mining methods and support facilities required to mine the leased coal given current economics, technology, and permitting requirements. The RFDS takes into account such things as safety, air quality, water quality, industry standards, and any other local, state, or federal requirements. The RFDS will be developed by BLM with input from the lease applicants and will be included in the EIS.
Reasonable Foreseeable Development Scenario
Energy analysts agree that the domestic and international demand for coal will increase for decades to come. Projections out to 2030 show coal consumption increasing by about 1.5 percent per year with most of this usage occurring as electrical-power generation. As an energy source, coal possesses the largest reserves and is generally the most economic source of power in the United States. New technologies have rendered coal a cleaner source of energy.
Coal is a hard, black, sedimentary rock formed over time from the remains of plant material. Heat and pressure convert the plant matter to coal, which is mainly carbon but contains hydrogen, oxygen, nitrogen and sulfur as well, and may contain other elements in trace quantities. Coal is ranked according to its level of alteration by heat and pressure, increasing in rank from lignite to bituminous to anthracite. As the ranking increases, so does the coal’s carbon and energy content. The coal reserves under application at East Lynn Lake are bituminous.
Argus Energy LLC and Rockspring Development have filed lease applications to mine approximately 13,089.55 acres of federal coal underlying federal land acquired by U.S. Army Corps of Engineers (USACE) at the East Lynn Lake Project, Wayne County, West Virginia. East Lynn Lake is an impoundment project created by the damming of the East Fork of Twelvepole Creek and is part of a Developed Recreation Area. Before any coal leases can be granted, coal-mining issues will be analyzed in a Land Use Analysis/Environmental Impact Statement (LUA/EIS). In the event that the Proposed Action is selected, the federal coal would be accessed from existing, adjacent mines located on private land owned by the applicants. Extraction would be accomplished by underground mining methods with the applicants cutting drifts from their on-going operations. No surface mining would occur.
To adequately assess the effects of the proposed action and to supplement other critical elements of the LUA/EIS which follow later on the preparation schedule, a Reasonably Foreseeable Development Scenario (RFDS) has been prepared and is presented here. An RFDS is a report which estimates anticipated development, production and reclamation activities that would accompany the implementation of the Proposed Action.
Argus Energy LLC (Argus) has approximately 7,624.60 acres under application for lease bordering a portion of the southern shore of East Lynn Lake. Rockspring has applied for roughly 5,449.92 acres positioned on the northern side of the lake. The Argus and Rockspring applications have been serialized WVES-50556 and WVES-50560, respectively. The coal rights covered by the applications were acquired by the USACE under condemnation authority in the early 1970’s. The Water Resources Development Act of 1999 effectively removed from the USACE all coal-mining consent authority and placed that authority with the BLM.
In November of 1999, the forerunner of Argus Energy, the Pen Coal Corporation, submitted to the BLM an application for the federal coal reserves underlying WVES-50556. Argus Energy became the applicant of record for WVES-50556 in February of 2003 when the Pen Coal Corporation sold its coal-mining assets in West Virginia to them.
Rockspring made initial application for their lease in 1999 and resubmitted a revised application in 2004, increasing the acreage to 5,449.92 from 1,832.12.
Argus' lease application is divided into three sections which represent extensions of existing logical mining units, designated as areas “A”, “B” and “C”. Rockspring’s application consists of six logical mining unit extensions. Figure 1 below shows a general overview of all the individual lease tracts, their sizes and their placement along the north and south shores of East Lynn Lake (Rockspring and Argus, respectively). A logical mining unit is an area that can be mined in an efficient and economical manner (typically by a single mining operation without the need to move equipment).
Along with their lease applications, the companies provided summaries addressing mining plans, geologic and hydrologic issues, subsidence, property descriptions and statements of qualifications. Based on recent and historical exploratory coal drilling data and data from the existing mines the applicants have compiled recoverable reserves figures for the federal coal underlying the application tracts.
Both applicants conduct active mining operations adjacent to the federal applications. Rockspring’s Camp Creek Mine is located to the northeast of the East Lynn Lake Reservoir and consists of underground mine workings, coal beneficiation and a coal refuse disposal facility. The Camp Creek Mine produces approximately 3 million clean tons of coal per year by means of room-and pillar extraction. Production occurs principally from the Winifrede (Coalburg) coal seam. The Winifrede (Coalburg) reserves typically are low-sulfur, high-BTU coals used principally for clean electric generation. The Camp Creek Mine operates at an average depth of roughly 250 feet below the surface and employs approximately three hundred people directly at the mine facility. The Federal coal would be extracted over a period of about 10 years.
Argus owns and operates two active and one inactive underground mines, three active and one inactive surface mines and one preparation plant, and two refuse disposal sites all located south of the East Lynn Lake Reservoir. The surface operations and the deep mines produce from the Winifrede (Coalburg) and the 5-Block seams. Argus’ underground workings operate at an average depth of 200-250 feet. Current operations produce about 2 million tons of clean coal per year. The Federal coal reserves within the Winifrede (Coalburg) coal seam and would be accessed from Argus’ currently inactive No.3 mine and the active No. 8 mine. Presently, there are 277 people employed directly by Argus with an additional 175 jobs performed by contract workers at their mining complex. The addition of the federal coal reserves would extend Argus’ mine life by an anticipated fifteen years.
Each company runs two shifts per day, a morning shift and an evening shift. The morning crews start at about 6:30AM and go until approximately 2:30PM. The evening shift works from about 2:30PM until 10:30PM. There tends to be some overlap between the shifts.
In the event that Federal coal leases are issued, neither applicant anticipates the need for additional hiring or surface construction. The federal coal reserves would be mined using the existing staffing and infrastructure at each mine.
Both applicants are proposing primary mining, only. Coal extraction would occur by underground mining using modern, continuous-miner room-and-pillar methods. No secondary, or pillar recovery, mining is proposed by either applicant. All future production from the Federal leases would be processed and shipped from facilities already present on company-owned ground. Each applicant justifies the issuance of Federal leases on the basis that the Federal coal resources will be lost if not developed from their existing, adjacent operations.
Regional bedrock consists of sedimentary rocks of the Pennsylvanian period. The Pennsylvanian is well developed in West Virginia, underlying approximately fifty-five percent of the entire state. Below is a description of that part of the Pennsylvanian section underlying the study area.
Surficial deposits within the area consist of alluvium and colluvium composed principally of sand and gravel with lesser amounts of silt and clay. Surface rocks belong chiefly to the Pennsylvanian Conemaugh group, although in this part of the state it is only the basal portion that remains. Immediately subjacent to the Conemaugh is the Allegheny formation, also of Pennsylvanian age
The Allegheny formation is bounded by the top of the Upper Freeport coal seam and extends down to the top of the Homewood sandstone. Within the study area the Allegheny Formation is represented by the Upper Freeport coal seam, the Lower Freeport coal seam, the East Lynn sandstone and the 5-Block (Lower Kittanning) coal seam. The Upper and Lower Freeport coal seams are sporadically present locally and are not considered commercially minable.
The East Lynn sandstone is a prominent member of the Allegheny Formation in the permit area, exhibiting channel-sand characteristics. This channeling has extended downward to the upper beds of the 5-Block coal seam. The East Lynn sandstone is coarse grained, massive, gray, and often contains quartz pebbles. The average thickness of the East Lynn sandstone is 50 feet, but can be as thick as 150 feet.
The 5-Block coal seam is often multiply bedded in the permit area, consisting of up to five mappable coal benches. Sandy shales, silty shales, homogeneously layered shales, and fireclays often cap and underlie the benches of the 5-Block coal seam. Over much of the application area, part of the 5-Block coal (the “A” split) has been removed by erosion during the deposition of the East Lynn sandstone.
Occurring approximately 10 feet below the "A" split is the 5-Block "B" Rider. The "B" Rider attains a maximum thickness of 4.72 feet, locally, containing partings of shale and bone. Occurring from 10 to 23 feet below the "B" Rider are the "B" and "C" splits of the 5-Block coal seam. Within the application area, the "B" and "C" splits are combined and so are often considered a single seam. The combined thickness of the "B" and "C" splits ranges from 1.4 feet to 8.7 feet. Occurring from 10 to 15 feet below the base of the "C" split is the "D" split of the 5-Block. The "D" split reaches a maximum thickness of 4.35 feet thick in the lease-application area.
Immediately below the Allegheny is the Pennsylvanian Kanawha formation. In Wayne County the Kanawha represents about 800 feet of sandstone (approximately 50 percent of the formation), shale, siltstone and coal measures. The Kanawha Formation extends from the top of the Homewood sandstone to the top of the Nuttall sandstone. There are some marine zones contained within the Kanawha formation consisting of calcareous, silty shales and impure limestones. The majority of the Kanawha is positioned below drainage within the study area.
Stratigraphic units of the Kanawha formation present on the application lands consist of the Homewood sandstone, the Stockton coal seam, Upper Coalburg sandstone and Winifrede (Coalburg) coal seam. The following is a brief description of the lithologies of these rock units:
The Homewood is a massive, gray sandstone frequently displaying crossbedding. Core drilling in areas surrounding the proposed mining area indicates a thickness for the sandstone ranging from 40 to 60 feet.
The Stockton coal seam is represented by two benches in the area. The Stockton "A" coal seam is found immediately to10 feet below the Homewood sandstone, separated from the Homewood sandstone by a shale unit where not overlain by the sandstone. The average elevation of the Stockton "A" coal seam within the study area is around 745 feet. The Stockton coal seam is positioned approximately 5 to 10 feet below the Stockton "A" coal seam. The Stockton coal seam is poorly developed and occurs sporadically within the study area, and is not considered commercially minable.
Upper Coalburg Sandstone:
The Upper Coalburg sandstone is approximately 55 feet thick in the application area, and occurs from 0 to 10 feet below the Stockton coal seam with shales and underclays occupying the interval between. This sandstone is massive, coarse-grained and gray in color. The Upper Coalburg sandstone is positioned immediately above the Winifrede (Coalburg) coal seam where this seam is present.
Winifrede (Coalburg) Coal Seam:
Known variously by both names, the Winifrede (Coalburg) seam is multiply bedded in the application area. This seam is represented by six coal benches which are inconsistently present across the study area. The total thickness of the Winifrede varies according to the presence or absence of the various benches. The coal benches individually range from 0.5 to 2 feet with individual parting thickness exceeding 4 feet. Across the application area, total seam thickness averages 57.03 inches with total sulfur content averaging about 0.56 percent.
Thin underclays usually underlie the coal seams in the section, representing bioturbated soil which supported vegetation growth and now exhibit highly impermeable characteristics. These clays are largely composed of illite, kaolinite and silica dust derived from the erosion of quartzose sand. The expandable lattice of the clay minerals allows swelling of these units as moisture is introduced, thus these units tend to form relatively impermeable boundaries to the vertical migration of ground water.
Description of Proposed Mining and Reserve Estimates
Both applicants propose to mine the Federal coal reserves from the Winifrede (Coalburg) seam by underground mining methods accessed from their existing operations. Both companies will develop room-and-pillar operations using a machine called a “continuous miner”, a remotely-operated vehicle which advances forward through the coal seam, mechanically breaking the coal and rock by means of a large, rotating drum-head studded with carbide teeth. The broken coal and refuse drops onto a built-in conveyor for loading onto waiting shuttles. Roof support is then installed, the ventilation is extended and the coal face is ready for the next advance. The roof will be supported with mechanical or resin-grout bolts or a combination of the two. In most cases, a single pass will remove a 10.5 to 11.5-foot swath of coal. The room-and-pillar configuration is developed as crosscuts are driven at 90-degree angles off the main entries. The mains and panels (rooms) generally consist of a 9-entry system projected on 60 feet by 80 feet centers. However, pillar sizes may vary in accordance with the U.S. Bureau of Mines’ Analysis of Retreat Mining Pillar Stability (ARMPS) modeling method and the appropriate pillar stability factors as described in the existing approved roof control plan. Crosscuts facilitate ventilation as fresh air passes through intake entries and is expelled through return entries. The average mining height of the Winifrede (Coalburg) is about six feet. A recovery rate of about fifty percent of the original coal in place is anticipated in the event that the federal reserves are mined.
The following is a breakdown of the federal coal reserves estimated to be present on the lease applications:
Tons Clean Recoverable
Impacts to the area from the proposed mining that may occur include subsidence of the surface and impacts to groundwater and surface water. Impacts that will occur include:
- Economic impact to the area, including increased revenues from mining royalties to the local governments, and
- Refuse processing and disposal.
Coal prices determine the revenue received by the Federal government from coal mining operations. A royalty rate of 8% of the coal sale price from underground mines is due the United States Minerals Management Service; 75% of this revenue is then transferred through the State of West Virginia to the local governments in which the mines are located.
Should all the recoverable coal be mined at the current price of about $43/ton, state and local governments would receive approximately $29 million over a period of 10 years and $39 million over a period of 15 years, for a total of $68 million.
Refuse is non-coal rock that will be generated as the coal and non-coal portions of the seam are mined. Refuse makes up about 50% of the seam, thus the volume of refuse generated by mining will be the same as the recovered coal, but because the density of the material is double that of coal the tonnages will be double that of the coal. We anticipate the generation of roughly 53 million tons of refuse if mining is permitted, which will be disposed in existing facilities on private land.
Ground subsidence over coal mines may occur as a result of inadequate pillar thickness for the depth of the mine, the thickness of the seam removed, and the thickness and lithologies of the roof rock. Extensive fracture systems or faults may intensify the effects of subsidence.
Pillar density of 50% and ground cover, or roof thickness, of the proposed underground operations is expected to be about 200 to 300 feet, with one to three thick, massive sandstones within that cover. These factors indicate that surface subsidence effects are unlikely.
The study area is drained principally by the East Fork of Twelvepole Creek and its tributaries. Stream valleys are covered with Quaternary-aged alluvium consisting primarily of sand and silt with lesser amounts of clay and gravel. The physical characteristics allow these deposits to function as aquifers which both store and transport ground water. These alluvial aquifers are present along the stream valleys of the study area and vary in elevation from 800 to 950 feet (MSL) within the areas in question. The thickness of these unconsolidated deposits is estimated at 20 feet. Alluvial aquifers tend to capture a portion of water derived from precipitation, which would otherwise leave the area as surface runoff. Water stored in the alluvium contributes recharge to underlying bedrock aquifers and may supply recharge to streams, thereby sustaining base flows.
Groundwater in the area occurs in both the unconsolidated alluvial materials and consolidated bedrock. Availability and movement of the water is controlled by both primary and secondary permeability features. Primary permeability is related to intergranular pore space of a lithologic unit. Secondary permeability consists of open fractures within and across lithologic units, which provides a pathway for the migration of ground water. It has been concluded that the primary permeability of the Pennsylvanian strata present in the lease application area is generally too low to allow for development as a water source. Water wells completed in strata having an absence of fractures will generally produce inadequate well yields in the area. There are domestic water wells producing from the Pennsylvanian strata in the area.
Natural fractures occur in rock units as a result of the erosion and removal of overlying rock layers and the resulting loss of compressional stress. These stress relief fractures are generally vertical along valley walls and are generally horizontal under valley floors. The presence and development of stress relief fractures provides pathways for the vertical and horizontal migration of ground water. The development of stress relief fractures allows for the interconnection of perched aquifers with underlying bedrock and alluvial aquifers. This then allows perched aquifers to contribute recharge water to underlying aquifers.
The apparent movement of ground water within the study area is toward the north-northwest, parallel to local dip. Two local geologic structures, the Doane Anticline and the Queen’s Ridge Syncline exert some influence on groundwater although topography may be a more controlling factor than structure. There may be re-direction of groundwater flow due to natural jointing systems and stress relief fractures present in the rocks. These fractures and jointing patterns may be modified and enhanced as a result of the removal of coal during mining.
In the event that mining occurs within the study area, the local groundwater regime might be affected. Underground mining of the Winifrede (Coalburg) may open existing fractures and jointing systems in the overlying strata, which in turn, might produce dewatering of overlying perched aquifers. Because all of the aquifers which may be affected by the proposed mining operation can be classified as perched aquifers, they receive their recharge as a direct result of seasonal precipitation. Consequently, the variation in seasonal precipitation rates will directly influence the amount of water present in the perched aquifers. Potential perched aquifers within the study area include the various splits of the 5-Block coal seam, Stockton and coal seams. The Winifrede (Coalburg) coal seam may also act as a perched aquifer.
Upon abandonment, wet seals would be constructed at the entries, allowing the movement of water through the seals and accumulation within the mined area. Outcrop seepage along the outcrop barriers in the down dip portions of the mined areas will be analyzed if it occurs.
Sulfur Fractionation analyses have been performed on the Winifrede/Coalburg in the proposed mining area. Sulfur may be found in coal and coal-bearing strata as organic sulfur, sulfate sulfur and pyritic sulfur. Organic sulfur is generally believed to be organically bound within the coal. Organic sulfur is not reactive and is not believed to affect the acid-producing potential of a coal seam.
Sulfate sulfur is produced as a result of weathering and oxidation of sulfide sulfur. Being a product of weathering, sulfate sulfur is not prone to acid production by oxidation.
Pyritic sulfur, however, has been associated with the potential acidity of strata and, in consequence, is the form of sulfur connected to acid mine drainage. The Winifrede/Coalburg coal seam contains a total sulfuric content of about 0.56 percent within the lease application area. Pyritic sulfur content for the Winifrede/Coalburg shows an overall weighted average of 0.05%, which is the limit of detection; in mining of the private coal adjacent to the Federal lands, alkaline waters have been produced; no AMD has been produced.
Safety zones, or buffers, will be established around and underneath certain surface structures to safeguard the integrity of those structures during mining. There are a variety of both federal and state laws with which the mining operators must comply. Within the study area, existing and future gas wells and the East Lynn Lake Reservoir will have the greatest effect on potential underground mining.
When the East Lynn Lake Project was acquired by the Department of the Army in the late 1960’s, the majority of the surface and mineral rights, including the coal deposits, were conveyed to the Department of Defense. The oil and gas rights remained vested in private ownership As a result, the coal industry will encounter about 144 in-place gas wells which must be avoided by a buffer zone. Both State and Federal regulations control the buffer to be left in order to safely isolate the two extractive operations; West Virginia requires a permit from a coal operator if the mine approaches within 200 feet of a gas well, while the Mine Safety and Health Administration (MSHA), Department of Labor permits if mining advances within150 feet of a gas well. Substantial tonnages of coal may be removed from a mining reserve base by wells – a 200-foot buffer around a single gas well in the study area would remove about 7800 tons of coal from production. In addition to an estimated 144 wells existing on the minable portions of the East Lynn Lake property, applications to drill two gas wells within one of the application areas were recently submitted to the West Virginia Department of Environmental Protection. This conflict could be an issue within the study area in the future, but the actual tonnage of coal lost to gas wells appears to be a function of mine design.
The establishment of buffer zones around and under the East Lynn Lake reservoir will be in accordance with State and federal regulations and guidelines. The Department of Labor’s Mine Safety and Health Administration has regulatory oversight regarding the establishment of safety zones around bodies of water. The applicants have proposed setting up set-back buffers around the perimeter of the impoundment extending outward a distance of 200 feet in all directions, creating a zone of no extraction beneath the reservoir. Additionally, outcrop barriers of about 150 feet will be established between the mine working and those areas of the applications where the coal seam outcrops at the surface.