ATT J-11

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Attachment J-11
Provide a Hydrologic Reclamation Plan (HRP) in the form of maps and/or narrative which
describes the steps to be taken to minimize disturbances to the hydrologic balance within the
permit and adjacent areas; to prevent material damage outside the permit area; to meet
applicable federal and state water quality laws and regulations; and to protect the rights of
present water users. The plan shall include:
A. Preventive and remedial measures to avoid acid or toxic mine drainage;
Acid-Base Accounting and Selenium analyses of the strata associated with the area proposed for
mining indicates only a few thin acid-toxic zones evident within the overburden. Overall, the
strata exhibited a net neutralization potential based on volume-weighted overburden analyses as
represented by core holes PX-06-15 and PX-06-17. The acid-toxic zones are specifically
addressed and identified in Attachments I-9, I-9D(1), I-9D(2), and J-6. These identified strata
will be segregated then blended with alkaline overburden material and selectively placed within
backstack areas (away from drainage courses) as described and illustrated in Attachment 0-8.
These materials will not be utilized for construction of the proposed Durable Rock Fills.
Sediment contributions from acid/toxic material will be avoided by handling the acid/toxic
material in accordance with Attachment 0-8. If acid/toxic sedimentation reaches a sediment
control structure it will be handled during the clean-out process as described in Attachment 0-8.
In the absence of water, the generation of AMD/toxic drainage from the materials will not occur.
B. Measures to assure the protection of the quality and quantity of surface and ground water
systems;
Quality
Measures to be taken to protect the quality of surface and ground water systems include the
following:
1) The properly sized and constructed sediment control structures: All sediment control
structures have been designed with a sediment storage capacity of at least 0.125 acre-feet per
acre of disturbed contributing drainage area as required by 38CSR2 §5.4.b.4. These
structures utilize retention time to allow for settling of suspended solids, including any
metals-laden particles.
It is not anticipated that any significant seepage would occur through the bottoms of the
proposed sediment control structures. This is in part due to the construction methods to be
employed for these sediment structures. The soils available on-site are to be compacted
during placement by tracking with construction equipment, which may include excavators
and bulldozers. It is anticipated that the compaction of unconsolidated materials during the
construction of the embankment would minimize the potential for seepage to occur.
Furthermore, the majority of sediment reaching these structures would consist mainly of claysized particles, which, by nature, would provide a relatively impermeable barrier to seepage
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Attachment J-11 (continued)
of impounded waters. In the event that seepage is noted at the proposed ponds and the
seeping waters are found to be in compliance, efforts to slow or stop seepage may not be
initiated unless it is determined that such seepage may threaten the structural integrity of the
embankment. In this case, seepage would be controlled to protect downstream areas.
In the event that the Inspector observes seepage from a sediment pond and determines that
the integrity of the structure is not threatened, a request may be made for a modification to
the NPDES permit to reflect deviations between proposed and as-built conditions. Such a
modification may involve relocation of the permitted outlet or establishing a new outlet at the
location of the seepage. Efforts to seal the sediment pond may be initiated upon recognition
of problematic seepage. Sealing of the pond may be accomplished by application of
bentonite or other suitable liner material. If necessary, treated water would be drained from
the pond to allow application of an impermeable liner. Materials to be utilized may include
compacted clay or Claymax blankets.
2) The use of temporary sediment control measures for periods of construction of in-stream
structures: Temporary sediment control such as hay bales, silt fences, etc. may be used
during construction for additional sediment control.
3) The blending of acid or toxic overburden, pond clean-out materials, and pit cleanings with
alkaline overburden in sufficient quantities to provide neutralization, and placement of the
blended materials on the mountaintop removal backstack (i.e., no acid or toxic overburden,
pond clean-out materials, or pit cleanings will be placed in durable rock fills): As previously
discussed in Attachments I-9 and J-6, overburden materials identified by ABA and Selenium
analyses as having a potential for generation of AMD/toxic discharges, and all pond clean-out
materials and pit cleanings are to be special handled in accordance with Attachment O-8 of
this Application.
4) Performing backfilling, regrading, and revegetation activities in accordance with proposed
contemporaneous reclamation and post-mining land use variances. All backfilling,
regrading, and revegetation activities will be conducted in accordance with Section O of this
Application to comply with the contemporaneous reclamation regulations within the
proposed permit area. This will in turn reduce the possibility of impacts to the surface and
ground water systems.
To ensure that the above measures are protecting the quality of surface and ground water
systems, all surface waters emanating from the proposed mining operation will pass through the
proposed sediment control structures (Sediment Ditches, Sediment Ponds, etc.) prior to discharge
from the proposed NPDES outlets. Water discharges will be monitored throughout the life of the
mining operation in accordance with the NPDES permit requirements. Any quality problems
encountered will be corrected as described in Attachment J-6, Item 4 (Water Quality).
Additionally, surface and ground water monitoring programs, as outlined in Section U of this
Application, will be utilized to identify any alteration in surface and ground water quality (or
quantity) in response to the proposed mining operation. Monitoring points for these programs
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Attachment J-11 (continued)
have been established at representative surface and ground water sites adjacent to the proposed
operation.
Quantity
Measures to be taken to protect the quantity of surface and ground water systems include the
following:
1) Surface runoff, which passes through the required sediment control structures, discharges
into the premining watershed. This maintains water availability to the pre-mining surface
water system. P & A Engineers and Consultants, Inc. has also completed a Storm Water
Runoff Analysis (SWROA). This study utilizes peak flow calculations for the receiving
watersheds for pre-mining, during-mining and after mining configurations. These peak flow
calculations were performed for a 25-yr/24-hr (4.67 inch) storm event and a 100-yr/24-hr (5.5
inch) storm event. The peak flow value for pre-mining conditions were compared to those for
the watershed in the other various mining configurations. The completed analysis is included
immediately following Attachment J-6.
The SWROA considers the impacts of proposed mining related features upon the peak
discharge volumes for the area. Mining related features affecting runoff patterns include
sediment control structures (ponds and ditches), rock check dams, and valley fill access roads.
As discussed in the SWROA, each of these features serves to increase the time of concentration
for runoff. As shown in Table 1 of the SWROA, the combined effect of the mining associated
construction results in lower peak discharge volumes for each of the subwatersheds for both
“during mining” and “after mining” configurations, as compared with pre-mining values.
2) Maximizing on-bench backfilling and construction of the durable rock fills: The coal seams
to be extracted on this operation may be considered as potential perched aquifers. It is
believed that any waters contained within the Upper, Middle, and Lower 5-Block, Stockton
“A” (Upper Stockton), Stockton (Lower Stockton), Upper Coalburg, Coalburg Rider, and
Coalburg Coal Seams is insignificant and does not significantly affect the ground water
supplies in the immediately adjacent areas. The ultimate volume of surface runoff reaching
the valley floors for recharge of alluvial and shallow bedrock aquifers will not be altered by
the proposed mining operation. After mining, the fractured overburden material is to be
placed in durable rock fills and on the bench of the Coalburg Coal Seam. This fractured
material will have a higher degree of porosity due to its unconsolidated nature, which
provides for increased infiltration of precipitation into the ground water system, thus
protecting ground water quantity.
3) Implementation of a phased mining plan: Surface and ground water quantity is further
protected by implementation of a phased mining plan (Attachment N-1.B.5). This approach
minimizes impacts to the overall surface and ground water systems as not all of the proposed
mine area, which includes portions of recharge zones for these systems, will be
simultaneously disturbed. As each phase progresses, the disturbed portions of the recharge
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Attachment J-11 (continued)
zones in the previous phase will be contemporaneously restored and possibly enhanced via
timely regrading and revegetation activities as detailed in the mining plan.
By protecting the quality and quantity of surface and ground water systems, these measures also
protect the rights of present water users. However, should it be proven that the mining operation
causes a diminution in the quantity and/or quality of the water supply of a current ground or
surface water user, as defined by DEP regulations the Applicant, Coal Mac, Inc. (dba Phoenix
Coal-Mac Mining, Inc.), will repair or replace the water source based upon a site-specific
evaluation of each occurrence. This may be accomplished by deepening existing wells, drilling
replacement wells, connecting a residence to PSD supply, or delivering another suitable supply of
water.
C. Measures to be taken to prevent, to the extent possible, contributions of suspended solids;
As with all areas of surface disturbance, the proposed surface mine operations will create a
potential for hydraulic transport of sediment from the disturbed area. The mining plan will
provide for the construction of sediment control structures to control the impact of sediment yield
for the proposed mining area. In addition, contemporaneous reclamation will limit the amount of
disturbance within the permitted area during mining.
Sediment control structures have been designed in compliance with the applicable storm event
frequency for the area to be disturbed by the proposed operations. With the exclusion of the time
of construction of the sediment control structures, all waters flowing from the disturbed areas
will pass through the sediment control structures. Temporary sediment control will be provided
at the time of construction of the sediment control structures. Temporary sediment control
structures may consist of straw bale dikes and silt fencing. All runoff from the disturbed areas
will be collected by a series of collection channels. The collection channels will either convey
the water to engineered sediment retention structures or will themselves serve as engineered
sediment control structures, which in turn outlet the runoff into either Left Fork of Pine Creek,
Pine Creek, Twin Branch, and Cow Creek. In addition, rock rip-rap and other suitable energy
dissipating devices will be employed to ensure that scouring does not occur downslope of the
retention structure outlets. Twice monthly monitoring for compliance with effluent limitations
will be performed for total suspended solids (TSS). If the TSS values are out of compliance with
the established NPDES limits, adjustments in treatment will be made at the sedimentation ponds
to insure compliance.
Sediment ponds and sediment ditches are to be periodically inspected to insure that appropriate
sediment capacity is available. Accumulated sediment in the sediment ponds and sediment
ditches will be removed upon reaching 60% of the designed sediment storage capacity. Sediment
excavated from these drainage structures will be placed in backstack areas for blending with
alkaline overburden materials as discussed in Attachments P-7.E and O-8 of this Application.
All sediment control structures have been designed with a sediment storage capacity of at least
0.125 acre-feet per acre of disturbed contributing drainage area as required by 38CSR2 §5.4.b.4.
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Attachment J-11 (continued)
Sediment control structures utilize retention time to allow for settling of suspended solids. This
is accomplished by positioning outlets and inlets at opposite ends of sediment control structures.
Should additional retention be required, installation of silt curtains or “booms” in the sediment
structures may be incorporated to effectively increase the flow path. The lengthened flow path
should increase the amount of settling of suspended solids prior to discharge.
D. Measures to control drainage and, if needed, a description of water treatment facilities;
Drainage control for the proposed operation will consist of a combination of combination
ditches, sediment ditches, groin ditches, sky ponds, and sediment ponds. Each sediment pond
will be constructed to provide drainage and sediment control for each entire respective durable
rock fill area. This will provide for sediment control for the entire fill during construction. After
construction the contiguous combination ditches will be used for sediment control for the top of
the fills and the downstream ponds will continue to be used as permanent sediment control for
the face of the fills. This results in over-designed sediment control for the final fill configuration.
All structures will be located as shown on the Proposal/Drainage Map. All sediment control
structures have been designed with a volume of at least 0.125 acre-feet per acre of disturbed area
as required by 38CSR2 §5.4.b.4. The outlet designs are calculated for a 25-year 24-hour storm
event. The combination ditches and groin ditches are designed on a 100-year 24- hour storm
event.
Temporary sediment control such as hay bales, silt fences, etc. may be used during construction
for additional sediment control.
The locations and plan views of all drainage control structures are shown on the
Proposal/Drainage Map provided in Section X of this Application and on the Pond design
drawings. Profiles and cross-sections of all structures are shown on individual design sheets
and/or drawings.
Based upon volume-weighted ABA overburden analyses presented in Attachment O-8 and as
discussed in Attachments I-9 and J-6, chemical treatment of drainage from the proposed mining
area is not anticipated. Physical treatment of drainage will consist of aeration by rip-rap lined
channels and settling of suspended solids. It is recognized that unexpected storm events may
occur in areas of exposed coaly materials and/or pit cleanings, thereby potentially introducing
acid/toxic runoff into sediment control structures. In the event that additional treatment methods
should be deemed necessary, the proposed sediment control structures would provide access for
such activities.
Potential chemical treatment methods may include installation of a chemical dispenser near the
inlet of the sediment structure. Typical treatment facilities may utilize soda ash briquettes or
other alkaline materials to increase pH and allow precipitation of metals within the sediment
basin. Soda Ash Briquettes and other “timed release” agents would be placed in the flow of
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Attachment J-11 (continued)
runoff whereby these materials would dissolve into the waters. Other treatment methods may
utilize quicklime or similar caustic agents that could be distributed based upon flow conditions.
E. Measures to be taken to restore, enhance, protect, or replace approximate premining
recharge capacity;
The measures to be taken to restore, enhance, protect, or replace approximate premining recharge
capacity include implementation of a phased mining plan and creation of enhanced recharge
zones.
Utilization of a phased mining plan minimizes impacts to the overall surface and ground water
recharge areas as not all proposed mine areas are to be affected at the same time. With a
maximum allowed disturbance of 35% (or 300 acres, whichever is least) combined with
contemporaneous reclamation activities (regrading and revegetation), the overall hydrology,
including recharge capacity, of each affected mining area is allowed to readjust with each
successive phase of the operation. The mining plan itself is designed such that the ultimate
surface water runoff patterns will remain relatively unchanged in response to the proposed
operation. This means that during- and post-mining surface water runoff will be directed into the
premining drainage areas. Accordingly, the ultimate volume of surface runoff reaching the valley
floors for recharge of alluvial and shallow bedrock aquifers will not be altered by the proposed
mining operation.
Replacement and enhancement of premining recharge capacity will be accomplished during
contemporaneous reclamation as the Coalburg mine bench is backstacked, and during
construction of the durable rock fills. Both activities will use the fragmented lithologic materials
generated during coal extraction. The proposed Backstack and Durable Rock Fill areas of the
proposed permit will have improved recharge capacity, as compared to premining areas, as the
fractured material will have a higher degree of porosity due to its unconsolidated nature. These
reclaimed and fill areas will enhance recharge to valley stress-relief fracture zones, and thus
alluvial and shallow bedrock aquifers, and to joint sets potentially connecting with deeper
bedrock aquifers. Evidence to support this conclusion has been presented in previous paragraphs
of this section as well as Section I of this Application.
Additionally, with the construction of sediment ditches along the perimeter of the Coalburg mine
bench, the increased retention time provided by the sediment ditches may allow for some
increased infiltration into any stress-relief fractures that may have been intercepted along the
mine bench. It is not anticipated, though, that this increased infiltration will significantly reduce
overall surface water runoff volumes as accounted for in the SWROA.
F. Measures to be taken to prevent, control, or mitigate the adverse impacts of gravity,
seepage, or pump discharges from underground mines and/or augering, if applicable;
N/A. The proposed permit is for surface mining by mountain-top removal methods.
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Attachment J-11 (continued)
G. Restore, protect or replace the water supply of present water users in accordance with
section 24 of the Act;
Utilizing all information presented in this Application, it is not believed that those residents who
reside along Cow Creek will be adversely impacted by this proposed operation. In the event that
residential water wells become impacted by the proposed mining operations, as determined on an
individual basis, Coal Mac, Inc. (dba Phoenix Coal-Mac Mining, Inc.) realizes its responsibility
to re-establish or replace pre-mining water supplies. This may be accomplished by deepening
existing wells, drilling replacement wells, connecting a residence to PSD supply, or delivering
another suitable supply of water.
H. Preventive and remedial measures to prevent any other potential adverse hydrologic
impacts identified in the PHC;
Due to the implementation of the mining plan proposed under this permit application, which has
incorporated AOC Optimization techniques to minimize impacts to jurisdictional waters, no
potential adverse hydrologic impacts are anticipated because of the operation of the proposed
permit. All parameters set forth in this permit will be adhered to in order to comply with all
regulatory agency guidelines.
In the event that the water-monitoring program should reveal any alteration in ground water or
surface water quality or quantity, directly related to the mining operations, remedial actions will
be initiated. Temporary sediment control measures and sediment control ponds will be
constructed prior to mining to eliminate suspended sediment from effluent of disturbed areas.
The ponds would provide access for chemical treatment, should it be determined that chemical
treatment is necessary.
The proposed durable rock fills and sediment control ponds have been located to minimize
impacts upon streams. The normal flow and gradient of stream channels, within the vicinity of
the proposed sediment ponds, will be altered by construction of these ponds. However, these
alterations will only occur within the bonded area of the confines of the pond and will not affect
off-site areas. The ponds are to be temporary sediment structures and will be removed upon
completion of mining and Phase II release. The stream segments will then be restored to the
approximate contours that existed prior to mining. Stream channel and riparian area restoration
will be performed in accordance with the Stream Restoration Plan submitted in the State 401
Water Quality Certification. Regarding stream flow, based upon existing durable rock fills in
surrounding areas, actual post-mining stream flows are likely to be more consistent at the toes of
the proposed fills. Based on the SWROA contained in Section J-6 of the Application, postmining peak discharges will be less than pre-mining peak discharges downstream of the sediment
ponds. A discussion of stream impacts is included in Attachment P-1 of this Application.
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Attachment J-11 (continued)
Outlets for all sediment control structures are to be constructed as close as practical to natural
drainways. The exit channel for sediment control structures are designed to be constructed with
rip-rap lining. The rip-rap will serve to retard erosion in the exit channel and will dissipate
energy in the waters flowing through the exit channel prior to reaching the natural drainways.
These drainways on steep slopes typically display channels carved into bedrock. Utilization of
existing drainways will minimize erosion on these steep slopes.
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