Background, Development and Contents of the PHC/CHIA Technical Reference Document

Deborah Dale, Hydrogeologist OSM-MCR Alton, Illinois

Topics:

• What is the PHC/CHIA reference document? • Background into the development of the

document

• Contents

What is the PHC/CHIA reference document?



Technical reference for the MCR Hydrologic Considerations for Permitting and Liability Release Probable Hydrologic Consequences (PHC) Determination Cumulative Hydrologic Impact Assessment (CHIA) Post-Mining Hydrologic Assessment (PHA)



Distributed by the Mid-Continent Technology Development and Transfer Team



Purpose of the document:

•

To provide a systematic approach within the MCR for the review and development of PHCs & CHIAs

•

Insight into the regulatory basis for bond release and post-reclamation hydrologic balance

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Authors of the document:



Brian Hicks, OSM-MCR



Wayne VanBuren, ADEQ



Timothy Walter, TX RRC



Deborah Dale, OSM-MCR

Background into the development of the guidance document

Milestones in the Development of PHC/CHIA Guidance Documents May 1980

•

The Determination of Probable Hydrologic Consequences and The Statement of the Results of Test Borings or Core Sampling

Milestones in the Development of PHC/CHIA Guidance Documents

•

December 1985 DRAFT Guidelines for Preparation of a Probable Hydrologic Consequences Determination (PHC)

•

DRAFT Guidelines for Preparation of a Cumulative Hydrologic Impact Assessment (CHIA)

•

DRAFT Appendices to PHC and CHIA Guidelines Documents

Milestones in the Development of PHC/CHIA Guidance Documents January 1997

• DRAFT

Managing Hydrologic Information: A Resource for Development of Probable Hydrologic Consequences (PHC) and Cumulative Hydrologic Impact Assessment (CHIA)

Milestones in the Development of PHC/CHIA Guidance Documents August 1999

• OSM’s Hydrologic Issues Team releases to the states

for review and comment a Phase I guidance document for baseline data (draft) April 2001

• Hydrologic Issues Team meets with states to review

a draft outline for a Phase II guidance document for writing PHCs and CHIAs (Austin)

Milestones in the Development of PHC/CHIA Guidance Documents Following the Austin meeting, several states raised concerns through the Interstate Mining Compact Commission (IMCC) about OSM’s proposed approach A main concern was that the preparation of any guidance document would carry a requirement for mandatory use rather than discretionary use

Milestones in the Development of PHC/CHIA Guidance Documents The IMCC and the Western Interstate Energy Board (WIEB) requested, and OSM agreed, to defer additional work on Phase II PHC/CHIA guidance until a State-Federal workshop on this subject could be held and the results assessed.

March 2002

• Intergovernmental Benchmarking Workshop on

PHC/CHIAs (New Orleans)

Milestones in the Development of PHC/CHIA Guidance Documents (57) topics relating to PHC/CHIA permitting hydrology (either concerns, issues or merely areas of interest) were identified during the course of the workshop

Milestones in the Development of PHC/CHIA Guidance Documents

•

January 2006 Draft Methodology for Review and Preparation of PHC Determinations and CHIAs in the Mid Continent Region

Draft Technical Reference for the Mid-Continent Region: Hydrologic Considerations for Permitting and Liability Release Probable Hydrologic Consequences (PHC) Determination Cumulative Hydrologic Impact Assessment (CHIA) Post-Mining Hydrologic Assessment (PHA) Distributed by the Mid-Continent Technology Development and Transfer Team September 2006

Hydrologic Considerations for Permitting and Liability Release Probable Hydrologic Consequences (PHC) Determination Cumulative Hydrologic Impact Assessment (CHIA) Post-Mining Hydrologic Assessment (PHA)



This guidance document has (4) main sections:



Probable Hydrologic Consequence (PHC)



Hydrologic Reclamation Plan (HRP)



Cumulative Hydrologic Impact Assessment (CHIA)



Post-Mining Hydrologic Assessment (PHA)

Probable Hydrologic Consequences (PHC) Determination

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Addresses the anticipated effects of the planned mining and reclamation on the quality/quantity of sw and gw systems



Overburden properties



Describe and characterize the subsurface strata

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Determine if AFM are present

PHC -



Disposal/storage operations

•

Spoil

•

Coal processing waste

•

Non-coal waste

•

Coal combustion byproducts

PHC -



Erosion and sediment control



Mining methods

PHC -

PHC -



Coal-bed methane recovery

Hydrologic Reclamation Plan (HRP)

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Detailed description of how to: 1) Minimize impacts to sw & gw systems within and adjacent to the permit area; and 2) Prevent material damage outside the permit area

*

HRP must include mitigation plans for hydrologic impacts - BTCA

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HRP Elements:

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AMD generation

• • •

Controlled placement of overburden Water management Mitigation options

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HRP Elements (continued) :



Non-acidic mine drainage

•

High TDS (i.e. sulfates, chlorides)

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Increased sediment loading

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Recharge capacity

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Disposal activities

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SW and GW monitoring

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HRP Elements (continued):



Water supply replacement

Cumulative Hydrologic Impact Assessment (CHIA)

a.k.a. the Chia Pet

Cumulative Hydrologic Impact Assessment (CHIA)



An assessment of the probable cumulative impacts of all anticipated mining in an area to assure the operation has been designed to prevent material damage to the hydrologic balance outside the permit area

Cumulative Hydrologic Impact Assessment (CHIA)



An assessment of the probable cumulative impacts of all anticipated mining in an area to assure the operation has been designed to prevent material damage to the hydrologic balance outside the permit area Hydrologic balance : Relationship between the quality/quantity of water flowing into, stored within, and discharging from a unit (i.e. drainage basin, aquifer, lake, etc.)

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Highlights of the CHIA section:

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When is a CHIA required?

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Relationship between PHC and CHIA



“Anticipated mining”

• Prospective mining operations + all existing operations (30 CFR 701.5 “cumulative impact area”)

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Highlights of the CHIA section (continued):



Cumulative Impact Area (CIA)

•

Definition of the CIA

•

Qualitative delineation of the CIA (sw and gw)



Highlights of the CHIA section (continued):



Cumulative Impact Area (CIA)

•

Definition of the CIA

• •

Qualitative delineation of the CIA (sw and gw) Quantitative check of the working CIA



Criteria for evaluating



Baseline conditions



Identification of hydrologic concerns

•

Water quantity issues

•

Changes in water quality

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Highlights of the CHIA section (continued):

 •

Material damage Definition (from previous draft CHIA guidelines, OSM 1985, 1997); examples

•

Functions of material damage criteria (standards, enforcement)



Methods for analysis of cumulative hydrologic impacts



Statement of findings

Post-Mining Hydrologic Assessment (PHA) Regulatory basis for release of performance bonds Post-reclamation hydrologic balance

DOES CURRENT WATER QUALITY MEET APPLICABLE STATE OR FEDERAL STANDARDS?

NO YES DO TREND ANALYSIS IS CURRENT WATER QUALITY BETTER THAN BASELINE WATER QUALITY?

+/0 CONTINUED MONITORING MAY BE REQUIRED RECOMMEND APPROVAL RECOMMEND APPROVAL +/0 DO TREND ANALYSIS YES OR SAME CONTINUED MONITORING MAY BE REQUIRED NO DO TREND ANALYSIS +/0 IS WATER SUITABLE FOR ITS INTENDED USE?

RECOMMEND DENIAL WATER-QUALITY TREND + IMPROVING 0 NO CHANGE - WORSENING YES NO RECOMMEND APPROVAL RECOMMEND DENIAL

Appendices: Appendix A : Glossary of water-related words, 153 p Appendix B : Outline of suggested minimum requirements for PHCs Appendix C : Outline of suggested minimum requirements for HRPs Appendix D : Outline of suggested minimum requirements for CHIAs Appendix E : Outline of suggested minimum requirements for PHAs Appendix F : Resources for processes/tools for determining impacts, 17 p (databases, software, training, etc.)