Post-Mortem Follow-Up Study

This study was designed to conduct a follow-up field review on permits with long term pollutional discharges that had been identified in the Post-Mortem Study. The Post-Mortem Study, undertaken in 1998 by the Pennsylvania Department of Environmental Protection (PADEP) with assistance from OSM, documented that the number of permits in Pennsylvania ultimately developing long term pollutional discharges has progressively declined since 1987. In this follow-up study, OSM and PADEP collect updated information on the status of the discharges on the 17 post-1987 permits with pollutional discharges identified in the 1998 Post Mortem Study.

• This study showed that the level of pollutional discharges from post-1986 surface mining permits is minimal. Only four permits (of 1047) issued since 1990 have resulted in post mining AMD discharges requiring treatment. None of the four had flows over three (3) gallons per minute and only one requires chemical treatment.

• Study data confirm that the vast majority of the long term pollution liability is the result of permits issued during the early program era from 1983 to 1986, and permits issued prior to Pennsylvania Program Primacy.

In 1998, OSM and PADEP conducted a Post Mortem Study. In the study, OSM and PADEP technical personnel evaluated the extent that post-mining pollutional discharges developed on permits issued since 1987. That study found that out of 1699 new permits issued by PADEP from 1987 to 1996, only 17 permits (or 1 percent), resulted in post mining discharges. That study also undertook a technical analysis of the 17 permits to assess whether cause(s) for the failures could be determined.

The field reviews and data collection for this study were conducted during September, 1999. A major drought has impacted the entire Pennsylvania coal region during the past year and was considered in the data analysis for the study findings. In cases where discharges had completely dried-up, the team recommended follow-up during more normal precipitation periods. In most instances where discharges were flowing, field review indicated additional monitoring and sampling was needed to establish a baseline for the discharges.

The attached appendix is a tabulation of the most relevant data elements gathered during the site evaluations. The data identify four permits issued since 1990 with discharges flowing at the time of the field reviews. These permits are now reclaimed, and while the flows of the discharges from these sites may have been impacted by the prolonged drought, the discharges were all very small (3 GPM or less). All were being effectively treated using passive systems at the time of the field review.

Land reclamation had been completed on some permits where the discharges were not flowing at the time of the OSM/PADEP inspection. Since prior sampling had indicated a low flow for these discharges, reclamation may have actually abated or eliminated the pollution problem. The OSM/PADEP follow-up monitoring effort will determine whether abatement has been actually been achieved.

This was follow-up study to the 1998 Post Mortem Study. It was planned to gather additional information and update the status of treatment on the 17 discharges. Since passive treatment methods have been used on some of these discharges, information relating to the effectiveness of the treatment system was also gathered. Joint OSM/PADEP Field reviews were planned for all 17 sites with the assistance of PADEP Permitting Personnel at each of the District Offices. Discharge flow data and samples will be gathered to provide updated site information. OSM and PADEP plan to update this data on an ongoing basis by continuing to monitor and sample the discharges. Treatment costs associated with these discharges will be determined utilizing site information and the "TREATCOST" program under development by PADEP.

Appendix A

Site #

Year Permit
Issued

Present Status of Permit and Amount of Bond Remaining For Permit

Present Discharge Flow Amt.

Present Type of Treatment
(if any)

Passive
Treatment
Possible

Estimate of Annual Treatment Cost

Impact to Receiving Stream if Not Treated

Any Provisions Established For Long Term Treatment

1

87

Bonds Forfeited; Site Reclaimed

dry / 5 GPM

dry –not treated

Yes

$ 10,441

Slight

2

88

$106,500 Bond Held ; Site is
Reclaimed.

dry / 5 GPM

Pro-Mac & Sodium Hydroxide

Yes

$ 9,100

Slight

3

89

$252,181 Bond Held: Site is Reclaimed

dry

Passive work done—discharge dried up.

Yes

$ 9,769

None/Slight

$47,731 in Bond Balance For Any Long Term Treatment Cost

5

89

Site Reclaimed ; Several Seeps are Directed to One Treatment Facility.

4 GPM

Chemical

Yes–Land is Available <5GPM

$ 386,473

Slight

10

92

$137,400 Bond Held ; Site Reclaimed
2 Discharges -TD5 & TD5A

TD5A- Dry

Passive–
Pyrolucite Trench on TD5

Yes

$ 43,128

Slight

13

88

$ 42,720 Bond Held ; Site Reclaimed

0.1 GPM

Chemical

Yes

$ 9,111

Slight

17

94

$40,650 Bond Held ; Site Reclaimed

3 GPM

Passive

Yes

?

Slight

18

96

$71,500 Bond Held ; Site Reclaimed

Dry

None

Yes

?

None

23

87

$36,300 Bond Held ; Site Reclaimed

5 to 7 GPM

Discharge is Pumped to Treatment Facility

No
Discharge is very near stream

$ 9,100

Severe

24

87

$124,880 Bond Held ; Site Reclaimed

<1GPM

Chemical Treatment is necessary for Mn (when needed)

Yes ;
Discharge is dry except in very wet periods

$ 9,100

none

25

88

$510,900 Bond Held ; Site Reclaimed

2 discharges 2 GPM #1
2 GPM #2
Discharges pre-existed but were worsend.

Chemical ; These Discharges Produce a Large Amount of Sludge Which must be disposed of on site

No

$ 52,799

Significant

26

88

$34,000 Bond Held ; Site Reclaimed

15 GPM

Anoxic Drain In Place

Yes

$ 9,526

Moderate

27

91

$260,940 Bond Held ; Site Reclaimed

< 1 GPM

Limestone Drain

Yes

$ 9,100

Slight

28 a

87

Site Reclaimed – Trust Fund Site

800 GPM

Waste Lime

No

$ 60,000

Severe

Treatment Trust Fund Established With DEP

28 b

87

Site Reclaimed - Trust Fund Site

25 GPM

Waste Lime

No

$ 60,000

Severe

Treatment Trust Fund Established With DEP

30

87

$106,600 Bond Held; Site Reclaimed, Alk/Mn Discharge.

10 GPM

Passive
Pond/Bog System

Yes

$ 41,542

Slight

32

88

$81,945 Bond Held ; Site Reclaimed

5 GPM

Passive;
Limestone Trench in Place

Yes

$ 83,059

Slight

The study included two permits, issued since 1987, that were actually part of an earlier attempt to abate a large discharge emanating from a deep mining complex. Shown in the above chart, the two Antrim Mining Company sites (28a and 28b) are the last two components of a 6-permit project to daylight a network of two deep mines, the Antrim #1 and Backswitch mines. The first of these permits was issued in 1982, when the state of knowledge in alkaline addition and prediction of postmining water quality was in its infancy. Ultimately six permits were issued up through and including the two 1987 permits (the first year monitored in the postmortem study). All of the permits used the same review criteria as the earlier 1982 permits; they were essentially part of the same remining project. Consequently, the two of these Antrim permits issued since 1987, and which were found to have resulted in worsening water quality on a preexisting AMD discharge, are not really representative of the permits issued during the study period and should be looked at as anomalies.

Nonetheless, the environmental impact of the Antrim permits has, if anything, been extremely favorable. Because these permits affected a large (800 gpm) preexisting discharge with severe AMD and the permits were not issued under Pennsylvania's Subchapter F (reminig) program, the operator became liable to treat the discharge to conventional BAT effluent limits. Treatment dramatically improved the water quality in Babb Creek and Pine Creek, an important trout fishery. The improved water quality spawned phenomenal local interest in restoring Babb Creek. Through the involvement of the Babb Creek Watershed Association (BCWA), local sportsmen, DEP, DCNR, and the PA Fish Commission, many additional AMD abatement projects ensued. Subsequently, the operator posted a trust fund of $1,500,000 to assure continued operation of the treatment plant. Recently, Antrim Mining Company has gone out of business but the Antrim AMD Treatment plant continues to meet effluent standards and complement a host of other water quality improvement projects on Babb Creek.

The treatment trust amount was based on an accounting of prior treatment costs and projected future treatment costs. The Antrim Treatment trust will also receive payments totaling $280,000 from U.S.A. Waste, Inc. (which bought a residual waste landfill that was previously owned by a related company of Antrim Mining). The trust is projected to earn sufficient money for continuing operation of the treatment plant. Currently, operation of the treatment plant by BCWA costs approximately $60,000/year.

Permits Issued 1990 to 1996

Site #

Year Permit
Issued

Present Status of Permit and Amount of Bond Remaining For Permit

Present Discharge Flow Amt.

Present Type of Treatment
(if any)

Passive
Treatment
Possible

Estimate of Annual Treatment Cost

Impact to Receiving Stream if Not Treated

Any Provisions Established For Long Term Treatment

27

91

$260,940 Bond Held ; Site Reclaimed

< 1 GPM

Limestone Drain

Yes

$9,421 / Yr.

Slight

10

92

2 Discharges -TD5 & TD5A

TD5A- Dry

Pyrolucite Trench on TD5

Yes

$ 43,128

Slight

17

94

$40,650 Bond Held ; Site Reclaimed

3 GPM

Passive

Yes

?

Slight

18

96

$71,500 Bond Held ; Site Reclaimed

Dry

None

Yes

?

None

The permits issued since 1990 have demonstrated a significantly smaller rate of production of post mining AMD. These four permits, of 1047 issued, represent only 0.4% that resulted in post mining AMD. And even more significant is the dramatic drop in the severity and volume of AMD, as can be identified by the chart data. The four permits resulted in five discharge points, two of which were dry at the time of this review. The largest flow was estimated at 3 GPM from one discharge; this discharge is successfully being passively treated. The other two discharges have a flow rate of 1 GPM or less; they are also being treated passively. The treatment cost estimate for site # 10 ($43,128), was calculated using data available for this discharge during chemical treatment. The site has since had a "Pyrolucite Trench" installed and appears to now be successfully providing treatment for the discharge. As noted in Appendix A, when DEP completes development of the new "Treat Mine" calculation methodology for estimating long term AMD treatment costs, the above chart data will be revised to more accurately provide data regarding passive treatment costs.