Transcript A TECHNICAL REVIEW OF THE NAS FINAL REPORT ON CCB PLACEMENT AT COAL MINES KIMERY C VORIES OFFICE OF SURFACE MINING.

A TECHNICAL REVIEW OF THE
NAS FINAL REPORT ON CCB
PLACEMENT AT COAL MINES
KIMERY C VORIES
OFFICE OF SURFACE MINING
PERSPECTIVE ON THE
SCIENTIFIC APPROACH
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OSM 11 YEARS OF TECHNOLOGY
DEVELOPMENT AND TRANSFER BASED
ON MAXIMIZING CCB EXPERTISE AND
EXPERIENCE
NAS 1 YEAR OF INVESTIGATION BASED
ON MAXIMIZING LACK OF BIAS BY
EXCLUDING CCB EXPERTISE AND
EXPERIENCE
IMPORTANT NAS FINDINGS
THAT ARE TECHNICALLY
WELL SUPPORTED BY LITERATURE
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CCB PLACEMENT AT ACTIVE COAL
MINES IN SUPPORT OF RECLAMATION
COULD BE AN APPROPRIATE OPTION
FOR USE/DISPOSAL
THE SCOPE OF SMCRA IS BROAD
ENOUGH TO COVER CCB PLACEMENT
IN SUPPORT OF RECLAMATION
IMPORTANT NAS FINDINGS
THAT ARE TECHNICALLY
WELL SUPPORTED BY LITERATURE
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SMCRA SHOULD BE AMENDED TO SPELL OUT
SPECIFICALLY WHERE AND HOW THE
EXISTING RULES APPLY TO CCB PLACEMENT
ON ACTIVE COAL MINES
OSM NEEDS TO SPECIFICALLY ADDRESS CCB
PLACEMENT AT FEDERALLY FUNDED AML
PROJECTS TO ADEQUATELY PROTECT THE
PUBLIC AND ENVIRONMENT
IMPORTANT NAS FINDINGS
THAT ARE TECHNICALLY
WELL SUPPORTED BY LITERATURE
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OSM AND EPA NEED TO WORK
TOGETHER ON FEDERAL RULEMAKING
RELATED TO CCB PLACEMENT AT
SMCRA MINES AND FEDERALLY
FUNDED AML PROJECTS
IMPORTANT NAS RESEARCH
RECOMMENDATIONS
Investigate environmental behavior
of CCBs placed at coal mines for
protracted time scales over:
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a range of climates,
hydrogeologic settings,
CCR types, and
mining and reclamation techniques.
IMPORTANT NAS RESEARCH
RECOMMENDATIONS
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Investigate fate and transport of
contaminants from CCBs placed at coal
mines and the potential for exposure by
humans and biological communities for
protracted time scales.
IMPORTANT NAS RESEARCH
RECOMMENDATIONS
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Investigate the improvement and field
validation of leaching tests to better
predict the mobilization of constituents
from CCBs in the mine settings for
comparison with post reclamation water
monitoring results.
NAS REPORT LIMITATIONS
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DOES NOT ADDRESS DATA APPLICABILITY RELATED
TO THE WIDE RANGE OF REGULATORY PROGRAMS
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SMCRA TITLE V ACTIVE COAL MINES
SMCRA TITLE IV AML PROJECTS
COAL MINE PITS REGULATED UNDER RCRA SOLID WASTE
PLACEMENT REGULATED UNDER STATE MINING PROGRAM
UTILITY DISPOSAL IN IMPOUNDMENTS AND LANDFILLS
UNREGULATED DISPOSAL AREAS NOT RELATED TO COAL
MINING
ACTIVE COAL MINE
APPLICATIONS
UNDER TITLE V SMCRA
ALKALINE SEAL TO PREVENT
ACID MINE DRAINAGE
CONSTRUCTION MATERIAL
AS COMPACT DURABLE BASE
Mine Road Building (Before Ash)
Mine Road Building (During)
Mine Road Building (After Ash)
NON-TOXIC FILL
TO REDUCE RECLAMATION COST
Mine Fill with Ash
ABANDONED MINE LAND
APPLICATIONS EITHER SMCRA
FUNDED OR STATE FUNDED
ALKALINE FILL
FOR ACID AML PIT
SOIL SUBSTITUTE FOR
AML RECLAMATION
ASH GROUTING FOR AMD ABATEMENT
OR SUBSIDENCE CONTROL
STATE FUNDED
AML PROJECTS
Waste Coal Converted to Power
AML Reclamation with FBC Ash
AML Ash and Harbor Dredge Fill
(Before)
AML Ash & Harbor Dredge Fill
(After Reclamation)
STATE RCRA PROGRAMS
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NORTH DAKOTA RELEASES FINAL PITS
FROM SMCRA MINES UNDER AN
INDUSTRIAL LAND USE WHERE IT IS
RELEASED AS A SOLID WASTE
LANDFILL REGULATED BY THE STATE
SOLID WASTE PROGRAM FOR
DISPOSAL OF CCBs.
NAS REPORT LIMITATIONS
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RELIANCE ON NON REPRESENTATIVE
EPA DAMAGE CASE DATA WITH NO
DEMONSTRATION OF APPLICABILITY
TO SMCRA REGULATED MINES
NO ADEQUATE ANALYSIS OF VOLUMES
OF EXISTING STATE WATER QUALITY
MONITORING DATA SHOWING NO
DAMAGE ON SMCRA MINES
NAS REPORT LIMITATIONS
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NO ADEQUATE ANALYSIS OF VOLUMES
OF SCIENTIFIC STUDIES SHOWING NO
DEGRATION OF WATER QUALITY ON
SMCRA MINES
NAS REPORT LIMITATIONS
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LACK OF ACKNOWLEDGEMENT OF DECADES OF SCIENTIFIC
STUDIES RELATED TO COAL MINING BY:
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U.S. Department of Energy’s (DOE) Combustion By-Products
Recycling Consortium
DOE researchers at the National Energy Technology Laboratory
Energy and Environment Research Center at the University of North
Dakota
Center of Applied Energy Research at University of Kentucky
University of Ohio
Southern Illinois University at Carbondale
Penn State University
West Virginia University and
CCB scientists and mining experts who wrote134 articles published
in 6 technical interactive forum proceedings by the Office of
Surface Mining over the period 1996 to 2005
CURRENT FEDERAL
RULEMAKING INITIATIVES
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LATE 2006 EPA WILL PUBLISH A
NOTICE OF DATA AVAILABILITY
CONCERNING RULEMAKING FOR
SURFACE IMPOUNDMENTS AND
LANDFILLS. A VOLUNTARY ACTION
PLAN SUBMITTED BY THE UTILITIES
WILL BE INCLUDED.
CURRENT FEDERAL
RULEMAKING INITIATIVES
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LATE 2006 OSM WILL PUBLISH A
NOTICE OF PROPOSED RULEMAKING
TO WRITE CCB SPECIFIC RULES FOR
SMCRA REQUESTING PUBLIC
COMMENT.
CURRENT FEDERAL
RULEMAKING INITIATIVES
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SPRING 2007 OSM WILL PUBLISH A
PROPOSED RULE FOR SMCRA TITLE IV
AND V UNDER EXISTING AUTHORITY
SPRING 2008 OSM WILL PUBLISH A
FINAL RULE FOR SMCRA TITLE IV AND
V UNDER EXISTING AUTHORITY