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7 Management of CCR in Reclamation Activities
Pages 155-176

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From page 155...
... As discussed in Chapter 5, reclamation practices are, by definition, regulated by the SMCRA, which established minimum national standards for coal mining. Thus, the use of CCR for minefill has to be viewed in the context of the general reclamation management activities and requirements.
From page 156...
... This results in comprehensive land-use plans that may be accompanied by zoning regulations or other performance standards. However, in many coal mining areas, such an approach to land-use planning does not occur.
From page 157...
... Use of CCR in Reclamation Operations Coal combustion residues have been used in the reclamation of both abandoned mines, as defined by Title IV of SMCRA, and active mines that are regulated under Title V The use of CCR in reclamation is not addressed specifically in the regulatory performance standards derived from SMCRA for either active or abandoned mines, although the regulations do allow coal mine waste to be discharged into underground mines as long as the plan is approved by the regulatory authority
From page 158...
... The extent to which the use of CCRs in reclamation operations is addressed by state regulations varies considerably from state to state. The disposal of CCRs in coal mines occurs under highly variable conditions, ranging from small quantities to massive minefills, from arid to wet regions, from remote to semiurban locations, from surface to underground mines, and from active to abandoned mines.
From page 159...
... Type of amendment -- fertilizers, limestone, fly ash, sewage sludge, or others b. Depth of application c.
From page 160...
... If CCRs are used to moderate the effects of acid mine drainage, additional factors such as acid-base accounting and blending CCR with spoil will have to be considered. The impacts of various CCR emplacement designs on groundwater flow and contaminant transport are discussed in detail in Chapter 3.
From page 161...
... Abandoned mine sites do not generally have to satisfy the post-mining land-use planning requirements that are part of the permit applications for active surface mines. One of the most common uses of CCR in abandoned mine reclamation is as structural fill material used to backfill abandoned pits.
From page 162...
... Regardless of whether the CCR is placed in an active or an abandoned coal mine, the issue of limiting the interactions of CCRs with groundwater should be a priority. There are a number of methods for reducing the interactions of CCR with water, although none will guarantee that CCRs remain totally isolated from infiltration.
From page 163...
... . Reclamation Bonding Before a mine permit can be issued and mining begun, a surface coal mine operator is required to post a reclamation bond.
From page 164...
... The use of CCRs in active coal mines has raised questions regarding the adequacy of current SMCRA reclamation bond requirements. Specifically, concern has been expressed about the length of the liability period and the adequacy of the remaining reclamation bond to treat any groundwater impacts that may occur after the bond is released.
From page 165...
... According to an analysis of regulations from 23 states by the Environmental Protection Agency (EPA) , five states have monitoring requirements for CCR disposal at mine sites that are substantially similar to SMCRA (USEPA, 2002c)
From page 166...
... Nevertheless, some broad concerns emerged in the committee's general assessment of monitoring activities at CCR mine placement sites. These concerns, which emerged from observations made during the committee's open meetings and site visits, include the appropriate placement of monitoring wells based on the location of CCRs and the characterization of subsurface flow paths and whether there were an appropriate number of monitoring wells to characterize and sample groundwater along these flow paths.
From page 167...
... Additionally, the committee observed sites at which background or upgradient wells were not situated in appropriate locations to achieve long-term baseline data for comparison. Monitoring well data from mine placement of CCRs is often difficult to interpret due to the influences of the mining process itself and the large volumes of spoil, which can impact water quality in ways similar to CCR.
From page 168...
... Field leachate data can be combined with hydraulic conductivity and hydraulic head data to provide an approximate assessment of contaminant flux. Comparing these data with groundwater quality and flow rates from nearby downgradient wells could provide information on adsorption, precipitation, and other attenuation processes.
From page 169...
... Some states have moved to electronic reporting data methods, which can speed the review process. Electronic reporting can also facilitate closer attention to water quality concerns if the data management system is capable of flagging exceedances for attention by state water quality staff.
From page 170...
... As discussed above, if wells are placed only at the permit boundary, water quality monitoring for the length of the bonding period may not detect a contamination problem, even if one exists. If downgradient contamination is detected, additional wells may have to be installed to assess the impact of CCR on groundwater resources.
From page 171...
... that might receive either direct surface or indirect subsurface discharge of CCR leachate. Direct surface discharges from mine sites are typically monitored in accordance with associated National Pollution Discharge Elimination System permit requirements.
From page 172...
... Because water concentrations of selenium are often not indicative of concentrations bioaccumulated in fish, invertebrates, and wildlife (Hamilton, 2002, 2003; Lemly, 2002) , the EPA is currently replacing its water quality criterion for Se with a tissue-based criterion (Federal Register EPA-822-D-04-001, Draft Aquatic Life Criteria for Selenium-2004)
From page 173...
... Indications that the established performance standards have not been met should trigger more intensive monitoring and, if warranted, the development of a remediation plan. SUMMARY Reclamation planning and monitoring are essential components of risk-informed CCR management at coal mine sites.
From page 174...
... Based on its reviews of CCR post-placement monitoring, the committee concludes that the number of monitoring wells, the spatial coverage of wells, and the duration of monitoring at CCR minefills are generally insufficient to accurately assess the migration of contaminants. Additionally, the committee found quality assurance and control and information management procedures for water quality data at CCR mine placement sites to be inadequate.
From page 175...
... In the event that surface-water quality impacts are detected, appropriate ecological monitoring may need to be implemented. Performance standards should be established for the aforementioned groundwater and surface-water monitoring points to ensure adequate protection of groundwater and surface-water quality.


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