Comments on RJ Corman Railroad Co. Draft Environmental Impact Statement

The Moshannon Creek Watershed Coalition has grave concerns about the impacts of this proposed activity to good quality local streams. The proposed rail alignment will traverse a large portion of the Moshannon Creek watershed, and will cross several headwater streams.

We cite the example of the Norfolk Southern railroad accident that spilled 42,000 gallons of sodium hydroxide that killed every living organism for several miles of the Portage Creek and Driftwood Branch of Sinnemahoning Creek in 2006 . This situation, while an accident, had a tremendous, irreparable effect on the water resources. Although the chemistry of the stream has recovered, and the biology of the stream has not yet recovered over 4 years later. Monetary contributions to the Fish and Boat Commission for re-stocking of fish cannot repair or replicate the aquatic community.

The rail alignment will be crossing over or near high quality trout streams such as Laurel Run, Black Bear Run, Six Mile Run and Black Moshannon Creek that are precious natural resources in the community. High quality streams that are not affected by acid mine drainage are rare in this area. Other streams such as Emigh Run have been restored through reclamation and treatment activities. We ask that any decisions carefully consider the impacts of a spill of just one rail car carrying frac water or other chemical such as peroxide. A spill of this nature has the potential to create irreversible harm to these streams. While such accidents are rare, the 2006 spill showed that these accidents can happen, and we ask that impacts to local streams be avoided. The EIS states that no Hazardous Waste will be shipped on the line, and we ask that a hazardous waste prohibition be a requirement for the use of the line. Also, while EPA considers frac water as residual waste, there have been documented cases of degradation to waterways from frac water, and frac water does contain radioactive elements, detergents, wetting agents, etc. that would be detrimental to the unpolluted ecosystem.

Also, in terms of water quality, we express concerns that construction activities to reactivate existing lines may disturb acidic materials present in the existing rail beds, or that construction of the alternate route may disturb acidic mine spoil. While the EIS finds that construction-related impacts would likely be insignificant in comparison to historic impacts, we do not believe that any additional new impacts such as acid mine drainage should be created by this project, and no further degradation of the waterways should be allowed. We ask that a plan to address these materials be developed to prevent any additional generation of acid rock drainage. We also ask that special care be exercised if earth disturbance were to occur in the eastern portion of the alignment where the waterways are mostly unaffected by acid rock drainage.

The E.I.S. states that expected train traffic will be 1-2 trains per day. What are the assurances that this use level will not change in the future, and will additional studies be required if traffic levels are to be increased?

We also express our concerns about public notice and advertising of this meeting, as we do not believe that the general public to be affected by the decision was made adequately aware of the study, this meeting, or the opportunity to comment. Publication in the Federal Register is not an effective way to inform the local population.

Moshannon Creek Watershed Coalition
P.O. Box 4
Osceola Mills, PA 16666