Pennsylvania Inventory Report
October 2000

OSM, with the cooperation of the Pennsylvania Department of Environmental Protection (PADEP) compiled an inventory of long-term pollutional mine discharges (commonly referred to as acid mine drainage or AMD). The function of the inventory is to pinpoint the geographic location where coal mine drainage problems occur, and to characterize the magnitude and abatement cost of water pollution for defined geographic areas. The purpose of this report is to provide a detailed analysis of the Pennsylvania inventory. The data and analyses will assist in establishing strategies for addressing the impacts of actual and potential discharges.

It should be noted that there is ongoing litigation (PennFuture) on the issue, filed (October 13, 1999) in United States District Court for the Middle District of Pennsylvania. The litigation, among other things, challenges the adequacy of Pennsylvania’s bonding system with respect to funding for long-term treatment of pollutional discharges.

• Permits currently being issued by the states are significantly less likely to result in long-term pollutional discharges. In a year-by-year analysis of permits issued since state primacy, a significant decline is noted in the number of permits issued that produce AMD. Permits producing AMD went from a high of 74 in 1984 to a low of 1 in 1995.

• On average, underground mines in the inventory contribute, by far, the most pollutant load of any type of mining operation. The average flow from underground mines in the Pennsylvania inventory is 454 gallons per minute (gpm). In contrast, the average flow from surface mines was 34 gpm and the average flow from prep plants was 48 gpm. (As noted elsewhere in this report, underground mine water data was primarily taken from pumped discharges and may not reflect final post-mining discharges.)

• The majority of the discharges in the inventory had relatively low volumetric flows. Approximately 41% the discharges were less than 5 gallons per minute, and 89% of the discharges in the inventory had flows of 50 gallons per minute or less.

• OSM estimated the annual treatment cost for the discharges on the inventory at a total of $17.7 million for active/inactive sites and $1.8 million for bond forfeited sites.

The Surface Mining Control and Reclamation Act of 1977 (SMCRA) requires a performance bond to be posted, and a sufficient amount retained, until reclamation obligations are completed. SMCRA establishes that the protection of water resources is an aspect of reclamation in Sections 508 and 519. Section 508 sets reclamation plan requirements and calls for measures to be taken during the mining and reclamation process to assure the protection of the quality and quantity of surface and ground water systems. Section 519 defines bond release procedures and mandates an evaluation, prior to bond release, of whether pollution of surface and subsurface water is occurring.

Since permits are not issued where pollutional discharges are anticipated, the initial amount of the bond is based solely on the cost of land reclamation. A problem arises when a pollutional discharge is created by the mining operation, because the cost of long-term treatment nearly always exceeds the amount of bond. Historically, bonds have not been adjusted when a pollutional discharge is encountered. Consequently, both conventional and alternative bonding programs have permits with long-term treatment liability that exceeds available funds.

Multi-State AMD Inventory Strategy As part of a comprehensive effort to address the problem of financing long term treatment costs in all states, OSM identified a need for reliable and consistent data to characterize the scope of the AMD bonding problem. To accomplish this consistently on a multi-State basis, OSM

convened a team to create a computerized inventory of long-term pollutional discharges. The objectives in creating such an inventory were to: 1) identify and locate all pollutional discharges; 2) accurately characterize the water quality and quantity of these discharges; and 3) establish general (not site specific) cost estimates for abating the long-term liability associated with treatment needs for defined segments of the inventory. Compilation of the AMD inventory was a joint effort of the states and OSM. In Pennsylvania, the state provided the inventory of active/inactive sites and OSM collected the data for bond forfeited sites.

Abatement costs for AMD sites in this Pennsylvania inventory study, as well as the AMD sites in the Appalachian Regional Inventory, 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 by Tetra Tech 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 developed a simplified version of the framework in a computer program. The program, called TurboTreat, produces cost estimates for treatment of AMD. The cost estimates generated by TurboTreat are not applicable to individual sites, but rather provide general estimates of cost for segments of the population.

This discussion of the Pennsylvania AMD inventory will be divided into five distinct areas. An analysis of the permits with pollutional discharges, an analysis of the characteristics of the discharges, a discussion of the cost estimates for abating the discharges, an analysis of the entities in the inventory and a review of the spatial characteristics of the discharges.

I. Permits

Permits in the inventory fall into two major categories. Those categories are: activity status and the type of mine. For the purposes of this report, activity status is limited to two classifications, active/inactive permits and bond forfeited permits. In the report, mine types are divided into four classifications. They are surface mines and ancillary facilities (surface mines), underground mines, preparation plants and tipples (prep plants), and refuse facilities.

The majority of permits in the AMD inventory are surface mines. Of the 265 permits in the Pennsylvania inventory, 209 (79%) are surface mines, 21 (8%) are underground mines, 5 (2%) are prep plants, and 30 (11%) are coal refuse disposal sites. Of the 265 permits in the inventory, 71(27%) have progressed to bond forfeiture status. The remaining 194 (73%) are in active/inactive status. In most cases, discharges from permits with a status of active/inactive are being treated to meet effluent standards; however, on bond forfeited permits treatment of the discharge is often non-existent or ineffective. (See Table 1 and Appendix A, Page 1.)

One of the most important findings from the review of permit data came from analysis of permits producing AMD by year of permit issuance. This review identified a steady decline in the number of permits producing acid mine drainage. As shown in Table 2 below and Appendix A, page 2, an analysis of active/inactive and bond forfeited permits by year of issuance indicates a significant downward trend in the number of permits that ultimately develop AMD. Further, a year-by-year comparison of the number of permits issued in Pennsylvania to the number of permits that developed pollutional discharges shows that the percent of permits issued that ultimately result in a pollutional discharge went from a high of 24% in 1984 down to a low of 1% in 1995. This shows that the state has developed technical capability over the years to successfully minimize the number of permits that produce AMD. PADEP is now working on strategies to effectively address treatment on existing discharges.

Discussion of the discharges in the inventory will be conducted in three categories. First discharges will be analyzed from the perspective of flow volumes. Next the discussion will address analysis of loading from various pollutants. And lastly, the inventory will be characterized by acid vs. alkaline discharges.

a. Flow Volumes

The AMD inventory includes 265 Pennsylvania permanent program permits. These 265 permits contain 409 pollutional discharges with a composite flow of 26,861 gallons per minute. Of the 409 discharges, 313 are from sites in the active/inactive status and 96 were from bond forfeited sites. Of the active/inactive sites, 250 of the discharges emanate from surface mines, 20 from underground mines, 9 from prep plants and 34 from refuse permits. Of the discharges from bond forfeited sites, 90 are from surface mines, 2 are from underground mines, none are from prep plants and 4 are from refuse permits.

Underground mine discharges represented the most significant flows in the inventory. Total flow volumes from underground mine discharges were similar to that from surface mines despite there being less than one-tenth the number of underground mine discharges (See Table 3. Further, the average flow from surface mines in the inventory was only 33 gallons per minute (gpm) while the average flow from underground mines was 454 gpm. Preparation plants and refuse piles also have high average flow rates with 408 gpm and 48 gpm respectively.

As inferred in Table 4 below, approximately 41 percent of all flow volumes in the inventory are five gallons per minute or less. The majority of the sites in the inventory have flows of 50 gallons per minute or less. Three hundred and sixty-two (89%) of the discharges are 50 gallons per minute or less, while only 47 (11%) are greater than 50 gallons per minute. (See Appendix A, page 6)

Flow ranges were also analyzed by mine type. This analysis reaffirmed that underground mines contribute disproportionately to the volume of pollutional flows. In the overall inventory, 12% of the flows are greater than 50 gpm; while only 9 % of the surface mines have discharges in that category. For underground mines, however, nearly half (45%) of the discharges in the inventory are greater than 50 gpm. In addition, of the eleven flows greater than 500 gpm, more than half (6) were underground mines while only 2 were surface mines.

b. Pollution Loading

Acid loading is a function of the volume of flow from the discharge times the amount of pollutants contained in the discharge. Loading in pounds per day is arrived at by the formula:

Review of the discharges in the inventory shows that underground mines are, by far, the largest producers of acid and other pollutants. For this report, the discussion of pollution loading focuses on two constituents, acid load and iron load.

Analysis of acid loading (Table 5 and Appendix A, pages 3, 4 and 5) revealed results similar to, but more dramatic than those from the analysis of flow rates. The data show that underground mines are, by a large margin, the greatest contributors of pollutant load in the inventory. The average acid load from an underground mine discharge is more than 10 times greater than from surface mines. The total acid load from underground mines is 66% of that from surface mines despite the fact that surface mines outnumber underground mines in the inventory by more than ten to one. Refuse piles are also large producers of acidity. Average acid load from refuse piles in the Pennsylvania inventory is 510 pounds per day, 6 times greater than from surface mines.

Review of iron loading from discharges in the inventory (Table 6 and Appendix A, page 10) provides results similar to those from analysis of acid load. The average iron load from underground mine discharges is 18 times greater than from surface mines in the inventory. Further, the total iron load from underground mines is greater (6103 ppd for underground mines as opposed to 5006 ppd for surface mines) than the total from surface mines despite there being more than 15 times as many surface mine discharges in the inventory.

c. Alkaline vs. Acid Discharges

The term acid mine drainage is commonly used to refer to all pollutional discharges from mining operations, even though many of the discharges in the inventory are alkaline in nature. These alkaline discharges frequently carry significant quantities of iron, manganese and other pollutants.

Of the 409 discharges in the Pennsylvania inventory, 162 are alkaline. These alkaline discharges are responsible for depositing a total of 5314 pounds per day of iron and 496 pounds per day of manganese into streams. The total number of alkaline discharges is 40% the total, they produce 32% of the iron and only 15% of the manganese in the inventory. Of the alkaline discharges, 137 are surface mines, 15 are from underground mines, 3 are from prep plants and 1 is from a refuse disposal site. (See Appendix A, page 7)

OSM’s estimate of annual treatment costs included estimated costs for chemicals, monitoring of the treatment system, sludge disposal, electricity consumption, and contingency costs to insure the long-term maintenance and operation of the facility. OSM estimated the total cost at $17.7 million for active/inactive sites and $1.9 million for bond forfeited sites. Total costs break-outs by mine type are surface mine $9.7 million, underground mines $4.9 million, prep plants $.8 and refuse disposal permits $4.2 million.

In addition to data related to water quality and quantity, the inventory also contains an indicator as to whether the discharge is treated or untreated. Analysis revealed that 88 of the discharges in the inventory are untreated. In these cases, estimated costs to abate the discharge must include the capital costs of acquiring property, building roads and other infrastructure, and constructing the treatment facility itself. The estimated capital costs for building treatment systems on untreated discharges in the inventory is $4.7 million. Of that, $4 million is on bond forfeited permits and $.7 is on active permits.

OSM developed Geographic Information System (GIS) coverage based on the data in the Pennsylvania AMD inventory. This coverage was used to develop maps showing the location and extent of the mine related pollution. Separate maps (Appendix C) were created showing discharge locations by flow, iron load and manganese load.

The average flow map on the next page displays the discharges in the inventory by flow rates. As can be seen from the map, AMD in Pennsylvania is concentrated primarily in a western end of the state in the bituminous coal fields. The heavier flows are located in Clearfield, Indiana, Cambria, Westmoreland, Washington and Greene counties.

Eighty-eight percent of the operators listed in the AMD inventory are no longer producing coal. OSM analyzed the permittees with AMD in the Pennsylvania inventory to determine which were still producing coal. This analysis was accomplished by linking permittees with AMD to OSM’s Applicant Violator System. This created an index of all permittees with long-term pollutional discharges and their related corporate entities. This index was next compared to the table of operators reporting coal production. The result indicated that 18 (12%) of the 150 unique permittees in the inventory reported production of 9.1 million tons in 1999. This production was reported on 21 different permits.

This analysis of the Pennsylvania AMD Inventory included discussion of the number and types of permits, the discharge flow volumetrics, the discharge pollution loading, the acid vs. alkaline characteristics of the discharges, the cost to abate the discharges, the geographic location of the discharges and the operators with AMD that are producing coal. Most significantly, the report found that Pennsylvania has developed the technical capability to issue permits that do not produce long-term pollutional discharges. In addition, the report found that, consideration of underground mine discharges, because of their high flow and load characteristics, must be a component in any successful strategy to address AMD.

The Field Office study indicates effort should be focused on improving pre-mining prediction of post-mining underground mine pool elevations and water quality characteristics. Due to the difficulty and complexity of accurately predicting the nature and extent of post mining discharges from underground mines, the inventory data for underground mines is taken largely from pumped outflows. This pumped water data may not accurately reflect the potential for post-mining discharges. To address this issue, OSM is planning a joint state/federal study aimed at improving pre-mining prediction of post mining pool elevations in underground mines.

Pennsylvania has maintained an inventory of long-term pollutional discharges since 1992. PADEP and OSM are in agreement concerning the need to maintain and update this inventory of long-term pollutional discharges on an ongoing basis. A plan is in place to insure addition of new sites as they are identified and deletion of sites where discharges abate.

The inventory database is stored in Visual FoxPro 6.0 (VFP6) format. The database currently contains two tables. A master file of permit information (one record per permit) and a detail file of information about each discharge (one record per discharge). There is a one-to-many relationship between the tables. The key field linking the tables is the permit number. A data dictionary is included as appendix B.

Analysis of the data was by direct query of the inventory in native VFP6 and SQL. In addition, VFP6 was used to create special summary reports from the database.

Appendices

Maps
(Click on the thumbnail images below to view the full-size version.)