Managing Coal Combustion Residues in Mines (2006) / Chapter Skim
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8 Synthesis of Issues for Planning and Regulation of CCR Mine Placement
8 Synthesis of Issues for Planning and Regulation of CCR Mine Placement
Pages 177-186
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From page 177... ...
has not specifically attributed significant environmental problems to CCR use in minefills, but better data are needed to fully characterize this issue. In abandoned mine lands (AMLs)
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From page 178... ...
The main advantages of CCR mine placement are (1) it can assist in meeting reclamation goals (such as remediation of abandoned mine lands)
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From page 179... ...
As described in detail in Chapter 6, site characterization should include a full description of the hydrogeological setting, including aquifer locations and groundwater flow patterns, surface-water drainage and flow, and soils and overburden characterization. The site characterization should also consider local factors, such as surrounding land use, proximity to sensitive surface waters, and designated future land use.
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From page 180... ...
Step Three: Developing a Long-Term Management Plan for the CCRs Mine placement of CCRs that is protective of human and ecological health requires the development of a long-term management plan, including careful attention to engineering design and monitoring. The following sections discuss CCR management issues to be considered during active mining and reclamation activities as well as those relevant to the post-reclamation period.
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From page 181... ...
In areas where CCR leachate may interact with surface water (directly or through groundwater interactions) more stringent requirements may be necessary to protect aquatic life (see Chapter 4, Sidebar 4.5)
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From page 182... ...
182 MANAGING COAL COMBUSTION RESIDUES IN MINES toring, there is potential for longer-term groundwater impacts from CCRs to go undetected under the normal reclamation bonding framework. Some committee members expressed concern that if significant contamination were detected after bond release, there would be no ready remedy available to the public.
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From page 183... ...
As noted in Chapter 5, any regulatory standards for CCR use adopted under SMCRA for active coal mining would most likely apply to remining activities but would not apply directly to CCR use in the reclamation of abandoned mine lands. To ensure adequate protection of public health and the environment, the committee recommends that placement of CCRs in abandoned and remining sites be subject to the same CCR characterization, site characterization, and management planning standards recommended for active coal mines.
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From page 184... ...
184 MANAGING COAL COMBUSTION RESIDUES IN MINES grams to engage members of the public, identify their concerns, and obtain their input on needed programmatic improvements. The committee recommends that any proposal to dispose of substantial quantities of CCRs in coal mines should be treated as a "significant alteration of the reclamation plan" under Section 511(a)
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From page 185... ...
Under SMCRA, the OSM and related state agencies that implement SMCRA currently have the regulatory framework in place to deal with CCRs used in mine reclamation and have considerable expertise in review, permitting, and management of mine lands. On the other hand, under RCRA, the EPA and its counterpart agencies at the state and local level have developed significant technical and regulatory expertise in monitoring and oversight of waste disposal operations (e.g., landfills)
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From page 186... ...
The scope of SMCRA is broad enough to encompass the use of CCRs at a mine site during reclamation activities, but neither SMCRA nor its implementing regulations explicitly address the use or placement of CCRs. As a result, regulatory gaps exist that create opportunities for unnecessary risks to water supplies and the environment.
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