This study is a continuation of a bond forfeiture study initiated last year, that inventoried and characterized bond forfeited primacy sites with pollutional discharges. The original study, conducted as a part of the Harrisburg Field Office’s (HAFO) 1999 Workplan, identified 52 forfeited primacy permits with a total of 80 long-term pollutional discharges. There were several objectives in updating the forfeiture inventory. Last year, field reviews were conducted during a substantial drought period in Pennsylvania. Our inspections found that 18 permits exhibited signs of recent discharges although there were no discharge at the time of the inspection. These 18 permits were revisited this year. Discharge information in our 1999 Acid Mine Drainage (AMD) database was also updated, verified and corrected where needed. Primacy forfeitures completed during the year were reviewed to determine if there were any long-term AMD problems that should be added to the inventory. Finally, additional reviews were conducted to determine the number of forfeited sites covered under Consent Order and Agreement (CO&A) that have long-term discharges. The information from these inspections and reviews were compiled into the updated Field Office AMD Database. General cost estimates were again applied to the discharges in the database.

° The updated inventory now identifies 55 primacy bond forfeiture permits with 84 long-term pollutional discharges. This is an increase of 3 permits and four discharges over the 52 sites and 80 discharges reported last year. The net increase is the result of normal validation and updating of the inventory and does not reflect a trend in AMD forfeitures.

° A new cost methodology was applied to the total discharges. Using this methodology, OSM estimated annual treatment costs for discharges on forfeited permits at $1,880,728 per year. Appendix A is a summary of the updated primacy bond forfeiture inventory.

 

Appendix A provides the updated total of permits with long-term pollutional discharges. The list now contains 55 permits with 84 discharges compared to a total of 52 permits with 80 discharges in 1999. The following is a summary of the updated information:

Field Office update and verification of the 52 permits in forfeiture inventory of efforts, resulted in removal of nine permits from the 1999 list. Eight of the nine permits were removed because water sampling determined they were now meeting effluent standards as set forth in the requirements of Title 25 PA Code 87.102. OSM’s review verified that one permit was pre-primacy (interim program) permits that should not be included in the post-primacy AMD Inventory. Appendix A lists these permits.

A follow-up Field review was done on the 18 permits that were identified last year as possibly having long-term discharges, but were dry during the 1999 study. The inspections found that eleven of the 18 permits had no long-term pollutional discharge problems. However, the remaining seven permits were found to have reestablished flow of Acid Mine Drainage (AMD) and the nine observed discharges have been added to the updated total shown in Appendix A. OSM will continue to monitor these sites.

Bond Forfeiture permits addressed under Consent Orders and Agreements (CO&A’s):

Appendix C identifies 60 permits that were visited as part of the CO&A study. These permits were reclaimed through third party, surety or through other means. However, there was no information on whether any sites had continuing AMD or whether any sites with AMD problems had been resolved. Four permits were found to have a total of five long-term pollutional discharges. The CO&A updating effort will be continued in the next oversight workplan and inspections will be done on BF permits covered in a CO&A where possible continuing pollutional discharges are indicated. The inspections will determine current status and, where AMD problems exist, water quality and quantity information for any pollutional discharges will be collected.

One recently forfeited permit was identified as having a long-term pollutional discharge and this permit was added to the inventory.

Nine permits with 11 discharges were removed from the AMD Inventory, and 12 permits with 15 discharges were added. As noted above, this results in a net increase of three permits on the inventory and a net increase of four pollutional discharges.

Fifteen new discharges were identified during inspections this year (Appendix D). Of those 15 discharges, three are being treated. Two of the untreated discharges were determined to have a significant impact on the receiving stream; 3 discharges have a moderate impact on the receiving stream; and the remaining discharges were determined to have minor or no impact on the receiving stream.

The information presented below lists the population and outcome of those permits reviewed. Again, a total of 55 permits are identified as having long-term pollution with a total of 84 known discharges.

*This table updates 1999 bond forfeiture information

Last year, the Field Office’s 1999 oversight workplan objective was to update current conditions of the discharges of all primacy forfeitures with AMD. This year, the Field Office’s 2000 oversight workplan included a study to continue to conduct field reviews on permits that were dry last year; on permits where transfers existed; and also sites with consent order and agreements were screened to determine post primacy bond forfeiture sites where long-term pollutional discharges existed.

Field reviews, in most cases, were conducted with PADEP staff, and data was collected on an AMD inventory discharge form where AMD discharges were found. For some permits, file reviews and personal knowledge were sufficient to determine that a permit did not have a post mining pollutional discharge.

Documentation AMD inventory forms were developed to gather specific information for each permit and discharge. These forms are also being used in all the Field Office oversight studies to collect and document information on permits with AMD problems. A detailed data base is being maintained for all sites identified for evaluation, so there is documentation of the final disposition of any permit initially identified as potentially having an AMD problem. The data base also contains all information collected about the permit and the individual discharges.

The findings presented in this report are based on a review of water quality and quantity data on permits with known discharges. The summaries provide general characterizations of the scope of the AMD problem on forfeited primacy permits. Data on the individual discharges, particularly where limited to a single sample, may not be representative, and certainly do not reflect seasonal variation in the discharges. The data base is set up to respond to queries regarding any of the collected data and specific permit and discharge information is available in the BF data base. For the assessment of impacts, the following terms were used:

Impact on the Receiving Stream - A statement of the potential impact on the receiving stream should the discharge go untreated, or real impact if the discharge is currently untreated. Options: None - no impact; Minor - barely detectable chemical change in the receiving stream water quality, but no impact on the biology of the stream; Moderate - detectable chemical change in the receiving stream water quality and some impact to stream biology; Significant - significant change in receiving stream water quality and obvious impact to the stream biology, possibly dead.

Abatement costs for this study were calculated based on a report by Tetra Tech EM, Inc. Tetra Tech was contracted by OSM to evaluate the financial factors associated with bonding long-term treatment of AMD. One of the deliverables of this contract was a report titled, "Methodology for Estimating the Costs of Treatment of Mine Drainage." The report establishes an extensive framework for calculating site-specific treatment cost for construction and maintenance of all types of treatment systems. The procedures are provided in various modules (work sheets), each calculating costs for a specific element of a treatment system. For a given treatment type, the user selects the modules that apply and, based on site conditions, completes the applicable line items within the modules. The values from each module are then carried forward to a summary sheet that provides the total cost estimate. A flowchart was also developed to assist in selecting a cost effective treatment type for specific water data and site conditions.

In order to apply the Tetra Tech framework to the AMD Inventory, a team of OSM hydrologists, engineers and computer specialists created a simplified version of the framework in a computer program called TurboTreat. The program, when applied to the inventory, produced cost estimates for treatment of AMD. The cost estimates generated by TurboTreat are not applicable to individual sites, but rather provide general cost estimates for segments of the population. These cost estimate methodologies are replaced by the previous methodology used in 1999, Acid Mine Drainage Control and Treatment - Second Edition, Chapter 23, Compiled by Jeffrey G. Skousen and Paul F. Ziemkiewicz).