A mine discharge along Dunkard Creek along the West Virginia-Pennsylvania border. Photo from Dunkard Creek Watershed Association.

My lengthy story in your Sunday Gazette-Mail tried to explain some of underlying water pollution problems that may have helped lead to the massive fish kill that has devastated Dunkard Creek up in North-Central West Virginia.

But I’m afraid it only scratched the surface of a huge, looming problem for the coal industry and for the West Virginia Department of Environmental Protection.

It’s called conductivity, and it’s a measure of how well a stream or creek conducts an electrical charge. But it is also an indicator of the amount of dissolved solids — chlorides, sulfates and the like — that are in water. These things can kill aquatic life.

And across the coal-mining counties of West Virginia, they are a big problem that WVDEP hasn’t even begun to try to deal with in any comprehensive way.

In Sunday’s story, I mentioned a letter that Derek Teaney, a lawyer with the Appalachian Center for the Economy and the Environment, had sent to WVDEP to comment on the agency’s plan for cleaning up the pollution problems in Dunkard Creek. Among other things, Derek pointed out that WVDEP knows that Dunkard Creek has a conductivity problem, but did not propose any fix for that problem.

Derek also pointed out that WVDEP has done exactly the same thing when writing stream cleanup plans for  other watersheds: The Upper Kanawha, the Gauley and the Coal.  In each case, WVDEP officials said they lacked enough information to include any fix for conductivity problems in the cleanup plans, called Total Maximum Daily Loads, or TMDLs.

According to Derek’s letter, written on behalf of the Sierra Club and the West Virginia Rivers Coalition, said:

WVDEP has still neither developed a TMDL for these streams nor created a plan to do so. WVDEP may not continue to delay the development of ionic toxicity TMDLs indefinitely or for unsupported reasons.

In fact, the U.S. Environmental Protection Agency has pointed to elevated conductivity downstream from valley fills in objecting to the issuance of new mountaintop removal mining permits, and explained:

“Recent data and analysis have revealed that downstream water quality impacts have not been adequately addressed by the permit, especially in light of clear evidence that effluent from valley fill sedimentation ponds is very likely to elevate conductivity and thus negatively affect healthy aquatic communities.”

EPA Administrator Lisa P. Jackson herself mentioned this problem in an interview with National Public Radio:

And it is true that much of the science shows that when you have a lot of, when you start to see a preponderance of stream miles filled in, you start to see higher conductivity levels, which is indicative of higher suspended solids, which starts to effect the aquatic ecosystems sort of from the bottom up.  And so activists and people who live in the area have raised concerns about why this practice had been allowed to continue.

And in fact, WVDEP outlined its own concerns about this problem in its most recent statewide water quality monitoring report, finalized last year:

[A]ll of the biologically impaired streams with “mining” identified as the source have undergone stressor identification in a TMDL development process. For each stream, the stressor identification process has identified ionic toxicity as a significant stressor … In each case, water quality data indicates elevated conductivity and sulfates contributed by mining discharges. Additionally, land use in affected watersheds is overwhelmingly dominated by mining activities.

As with the pollution problems on Dunkard Creek that pre-dated this month’s terrible fish kill, WVDEP knows about this issue … stay tuned to see what, if anything, the agency decides to do about it.