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E Side By Side Comparison RCRA to SMCRA
Pages 229-252

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From page 229...
... E Side-by-Side Comparison of RCRA to SMCRA S taff from the Office of Surface Mining, Reclamation and Enforcement (OSM) (within the U.S.
From page 230...
... 230 MANAGING COAL COMBUSTION RESIDUES IN MINES RCRA References SMCRA References impacts to the permit area and adjacent areas during and after mining. This is the probable hydrologic consequences (PHC)
From page 231...
... Location is critical hydrologic, geologic, and other information to the ability to detect effects of ash in the permit application. The plan must placement before the effects can spread provide for the monitoring of parameters widely, thereby adversely affecting current provide for the monitoring of parameters or future uses of the water resource.
From page 232...
... 232 MANAGING COAL COMBUSTION RESIDUES IN MINES RCRA References SMCRA References B Parameters: Samples are to be analyzed B
From page 233...
... APPENDIX E 233 RCRA References SMCRA References RCRA References: Part 258.53(c)
From page 234...
... 234 MANAGING COAL COMBUSTION RESIDUES IN MINES RCRA References SMCRA References has been adversely impacted by contamination, diminution, or interruption proximately (defined as a result that directly produces and event and without which the event would not have occurred) resulting from the surface mining activities.
From page 235...
... APPENDIX E 235 RCRA References SMCRA References not have occurred) resulting from the surface mining activities.
From page 236...
... 236 MANAGING COAL COMBUSTION RESIDUES IN MINES RCRA References SMCRA References locations. It shall describe how the data may be used to determine the impacts of the operation upon the hydrologic balance.
From page 237...
... the RA has made an assessment of the Probable Cumulative Impacts of all anticipated coal mining on the hydrologic balance in the cumulative impact area and has determined that the proposed operation has been designed to prevent material damage to the hydrologic balance outside the permit area. SMCRA References: 30 CFR Part 773.15 ­ Written Findings for Permit Application Approval A
From page 238...
... Location Restrictions: Due to their C Location Restrictions: particular sensitivities, sites of specific Each permit application must include a characteristics are not amenable to the description of the existing, pre-mining permanent and irreversible nature of ash environmental resources within the proposed placement and cannot be used for ash permit area and adjacent areas that may be placement.
From page 239...
... o Alternate water sources 4. Seismic Impact Zones: Seismic move- o PHC ments can cause ash to unexpectedly o CHIA contact surface or groundwaters, with o Hydrologic reclamation plan subsequent harm to human health or the o Surface and groundwater environment.
From page 240...
... 240 MANAGING COAL COMBUSTION RESIDUES IN MINES RCRA References SMCRA References artificial components responsible for lower aquifer impacted by mining. preventing releases from the ash The description shall include the placement.
From page 241...
... APPENDIX E 241 RCRA References SMCRA References The following are purposes given in the Act (30 U.S.C.
From page 242...
... 242 MANAGING COAL COMBUSTION RESIDUES IN MINES RCRA References SMCRA References 30 CFR Part 701.11(d) ­ Application of Standards Part 773 ­ Permits and Permit Processing Requirements Part 777.15 ­ Completeness of Application Part 778.17 ­ Permit Term Part 779.11 ­ Characterization of Environmental Resources Part 779.1, 780.1, 783.1, 784.1 ­ Scope of Requirements for Permit Application.
From page 243...
... CCB (ash) characterization and leach testing would be required when the permit application involved CCB placement under the provisions of 30 CFR 780.21(f)
From page 244...
... Baseline Monitoring: Prior to placing ash at a mine site, Each permit application must include a groundwater monitoring is to be conducted description of the existing, pre-mining to establish "baseline" conditions for environmental resources within the proposed comparison with future monitoring data. permit area and adjacent areas that may be
From page 245...
... The permit application must include the following baseline RCRA References: Part 258.53(3) information upon which the mining and Establishing background reclamation plan must be based: · General Environmental Resources Information including the cultural, historic, and archeological resources, 30 CFR §779.12.
From page 246...
... 246 MANAGING COAL COMBUSTION RESIDUES IN MINES RCRA References SMCRA References related to Fault areas, Seismic Impact Zones, and Unstable areas) in the proposed permit and adjacent areas down to just below the coal seam or any lower aquifer impacted by mining.
From page 247...
... APPENDIX E 247 RCRA References SMCRA References standards and a plan for fugitive dust control RCRA References: No comparable practices. All other mines must submit an air requirement under Subtitle D (see, pollution control plan including an air Part 264.30 (j)
From page 248...
... 248 MANAGING COAL COMBUSTION RESIDUES IN MINES RCRA References SMCRA References Therefore, there is not a need for additional risk assessment, beyond what is already required by a SMCRA program on a permit by-permit basis.
From page 249...
... APPENDIX E 249 RCRA References SMCRA References Parts 773.6, 840.14, 842.16 ­ Availability of Records Part 773.6(d) ­ Public Availability of Permit Applications Parts 840.15, 840.16, 842.11 ­ Public Participation in Enforcement Part 842.12 ­ Requests for Federal Inspections Part 842.14 ­ Review of Adequacy and Completeness of Inspections B
From page 250...
... 250 MANAGING COAL COMBUSTION RESIDUES IN MINES RCRA References SMCRA References the exceedence results from a source other whatever steps are necessary to ensure that than the ash placement or that the exceedence the public health and environment are results from error in sampling, analysis, protected based on compliance with statistical evaluation, or natural variation in applicable performance standards, permit groundwater quality. If the exceedence is terms and conditions.
From page 251...
... APPENDIX E 251 RCRA References SMCRA References continue throughout the post-reclamation protection or replacement of water rights, period. These activities are to include and to support the approved post-mining evaluation of results against the performance land uses in accordance with the terms and standards specified in Item II, above, and conditions of the approved permit.


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