Operation, Maintenance, & Replacement of AMD Passive Treatment Systems

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Presented by Pam Milavec

Where we are now

Mine Reclamation August 12, 2008

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Where we’re heading

Where have we been?

Why Operation and Maintenance?

 Currently more than 259 systems in operation with a public investment of over $77 million  Experience has shown that passive systems have routine operational needs, have expected and often unexpected major maintenance requirements and will eventually need to be replaced  Failure to provide for OMR will result in the loss of restored water resources and public investment

Terms

    Construction: Cost to build the treatment system.

O & M: Operation and maintenance activities including inspections, sampling, sample analysis, flushing, scheduled maintenance, and non-catastrophic unscheduled maintenance.

R: Single replacement of the system. Projected costs may approach original construction costs.

O, M & R: Combined operation, maintenance and replacement costs.

O, M & R Plan Should Include

 Narrative describing O, M & R  Maintenance agreement with all parties, including property owners  O, M & R Site Map Flushing points, sample points, BMPs  Site specific instructions  “As-built” plans

Long-term Cost Analysis

Information Sources: AMD

 DEP/BAMR -actual construction and O & M costs for existing systems plus estimated replacement costs  NRCS - project bid cost plus estimated O, M & R  Stream Restoration Inc. – estimated O, M & R for existing projects  Hedin Environmental - estimated construction and long-term O, M & R for Babb Creek system

Average Annual Factors for AMD Treatment Systems *

       Vertical Flow Systems.....

………… ..... 5% Anoxic Limestone Drain Systems....... 4% Compost Anaerobic wetlands............. 4% Pyrolusite© Systems........................... 3% Open limestone channels.................... 1% Lime sand addition programs..….….... 33-50% Automated lime doser......................... 13%  OMR Workgroup Average………….….4% * Annual percentage of construction costs

Breakdown of O, M & R for Vertical Flow Systems

 Routine operations (sampling,........... 20% inspections, flushing)  Water sample lab analyses ............... 10%  Maintenance – repairs & supplies ..... 30%  System reconstruction......................

40%

Total O, M & R...............................

(65% DEP provided, 35% local)

100%

Guiding Principles for Projects in Pennsylvania

True Sustainable Operation, Maintenance & Replacement is based on LOCAL COMMUNITY Ownership & Involvement The goal is a system of healthy INTERDEPENDENCE & PARTNERSHIP between government and local sponsors

OMR Support Strategy

 Local Sponsors provide routine operation and maintenance  Maintenance needs assisted by local industry, local government and/or BAMR construction staff  DEP provides funding for more significant maintenance and eventual system replacement

Where are we now?

Present Status:

       GG projects now require OMR plans as a deliverable GG project applications that adequately address OMR receive a higher score, particularly when non-government sources are utilized Local sponsors are expected to provide routine operations GG has an OMR project-type category and provides funding for maintenance and replacement on a competitive scoring, annual grant, basis WPCAMR has received a grant to fund lab analyses WPCAMR has received 2 Quick Response grants and has applied for a third in the 2008 grant round BAMR has put together OMR task force to evaluate existing BAMR passive treatment systems

Growing Greener O, M & R Category: Existing Facilities

 Annual grant cycle  Competitively Evaluated and Scored  Evaluation and scoring criteria O, M & R plan conceptually sound Public-private support with local government, residents, industry, etc.

Maintenance/replacement essential for continued environmental benefit

WPCAMR Lab Analysis Grant

     $166,000 grant provides funding for lab analysis by local labs: Mahaffey Lab (Grampian) & G&C Lab in Summerville Currently covering 7 counties: Allegheny, Armstrong, Butler, Clarion, Clearfield, Indiana and Jefferson Requires an OMR plan Has been underutilized Grant expired 6/30/08; an extension has been requested but no decision has been made yet

WPCAMR Quick Response Grant

       Started in 2006 A mechanism to quickly provide GG funds to local sponsors when failure to act quickly will likely result in serious

environmental consequences or will contribute to further damage of a project

Current grant has a remaining balance of $189,000 and has been extended to 6/30/09 2007 grant adds $100,000, with an end date of 2010 WPCAMR has applied for a new grant for the 2008 round of GG Applications are available on the GG web site – search under “quick response” key words The application process is relatively streamlined and straightforward

Quick Response (continued)

     Completed applications, with a contractor’s cost estimate attached, are submitted to the DMO Watershed Manager Watershed Manager and District Mining Manager must approve project and forward to WPCAMR WPCAMR sends letter to applicant stating whether funding is approved or not If approved, applicant has contractor complete repairs, Watershed Manager reviews and approves repairs, WPCAMR then disperses funds to applicant and applies to DEP for reimbursement Must have signed landowner access and permits, if needed

Types of Projects funded:

      Damage caused by storm events – damage to ditches, berms, intake structures and spillways (most frequent cause of funds needed has been damage due to storm events) Non-storm related berm and pipe damage Sludge removal from compost Replacement of valves Repairs to a stream bank stabilization project after a storm event (non-AMD project) 11 projects funded so far; costs have ranged from $2,800 to $55,000

BAMR’s OMR Taskforce

      Established to address OMR needs of BAMR-constructed passive treatment systems In Cambria office, 2 teams have been established that include engineers and geologists Have completed 2 evaluations and are currently working on 2 more Most problematic sites are given top priority, but the goal is to develop an OMR workplan for all 24 systems designed and constructed by the Cambria Office Harrisburg staff is focusing on BF projects designed there, while Wilkes-Barre staff will be working on projects built by BAMR in their District Reports will eventually be posted on BAMR’s web site

BAMR AMD Project OMR Report Format 5/14/08

Project Background

Project number, name, twp., county, receiving stream Identify what the goal of the project was and general background of the project Project info Project design info – design methodology, design flow and quality Project description - describe the treatment system including each individual treatment cell Status of routine operations, past maintenance and retrofits Status of restoration efforts in the watershed and partner viability Property owner info and status of BAMR access rights Attachments: (if on-line, links may be used to locate this info) System water quality data spreadsheet in a standardized format Stream survey report or data, if available (post-construction) As-builts (to be completed by Inspectors/Designers/Surveyors) Monitoring map indicating sample point ID and location O & M/monitoring plan Topographic map depicting treatment system location Directions to site

Performance Evaluation and Recommendations: Evaluation:

Water quality data trends (may want to depict with graphs or other visuals) Results of field review (include a discussion of any analysis or field tests completed by BAMR as part of this evaluation) Summary of current status of system Discuss whether project goals were accomplished

Recommended Options:

Retrofit/major repair to be designed in-house and bid out Retrofit/major repair to be designed through the passive design consultant contract and bid out Retrofit/major repair to be undertaken by the BD crew Continue current operation Modify current operation, including operational or monitoring modifications Abandon system, remove treatment system and restore area

Scope of Work for Recommended Option (if applicable)

Narrative or list of work needed Estimated cost (identify funding source, if known) Materials list (type and quantity), for BD projects Attach needed drawings or schematics

Post-construction follow up Report

Once recommended work is completed, a follow-up report is to be completed and attached that includes costs and success of recommendation

Each time a performance evaluation is initiated, the above sections should be repeated under the new date

Where are we going?

Draft Set-Aside Position Paper: Plan to Address OMR

    Successful Growing Greener Applicants to handle routine operations DEP to provide mechanism to fund emergencies and non-routine maintenance; current Quick-Response program provides a template DEP to develop appropriate application to seek grants for complete or partial system replacement Funds also will be provided to BAMR for Commonwealth-constructed systems and “orphaned” systems

Funding

    DEP has committed $2 million this year to support OMR Set-Aside funding increases under re-authorized SMCRA will likely be a source of funding for DEP support of OMR The DEP will make funding decisions based on OMR costs for current systems and what the projected costs will be for future systems; current estimates are that the OMR need is $2 million/year, thereby requiring approx. $46 million to be deposited into an interest-bearing fund, based on current financial scenarios – just for the passive systems currently operating Set Aside funds used in this manner will not be available to construct treatment facilities, thereby reducing the overall funding available for AMD abatement and treatment projects