FINAL
DRAFT
Coal
Mining
August
12,
2004
Page
1
of
37
Coal
Mining
(
40
CFR
434)
Detailed
Investigation
for
2004/
2005
Planning
Process
Executive
Summary
During
the
Screening
Level
Review
phase
of
the
2004/
2005
planning
process,
coal
mining
was
one
of
eight
industrial
categories
identified
solely
through
Factor
4
concerns.
Issues
driving
the
concerns
include:
1)
stormwater
runoff,
2)
high
discharges
of
total
dissolved
solids
(
TDS)
and
total
suspended
solids
(
TSS),
and
3)
manganese
discharges.
Based
on
information
reported
to
the
Toxic
Release
Inventory
(
TRI)
and
the
Permit
Compliance
System
(
PCS),
toxic
discharges
from
coal
mining
operations
are
low
relative
to
other
industrial
categories.
In
addition,
a
few
facilities
generally
drive
the
toxic
weighted
pound
equivalent
(
TWPE)
loading
estimates
for
this
industry.
The
pollutants
driving
the
TWPE
estimate
for
these
few
facilities
are
mercury
and
arsenic.

The
information
in
the
record
at
this
time
does
not
support
a
decision
to
revise
these
effluent
guidelines.
In
the
event
that
stakeholders
provide
additional
data
and
supporting
information
during
subsequent
review
cycles,
EPA
will
reevaluate
them
at
that
time.
In
the
absence
of
revisions
to
the
effluent
guidelines,
these
concerns
could
be
addressed
through
improved
information
dissemination
and
outreach.
This
could
include
a
fact
sheet
with
answers
to
frequently
asked
questions
(
FAQs),
including
the
names
of
current
contacts
within
EPA's
Office
of
Water.
The
Agency
could
announce
the
availability
of
this
fact
sheet
at
the
regular
meetings
for
permit
writers
and
pretreatment
coordinators
held
by
the
Office
of
Wastewater
Management
(
OWM)
and
through
internet
postings
and
email
alerts
to
the
Engineering
and
Analysis
Division
(
EAD)
stakeholders
mailing
list.
In
addition,
EPA
could
alert
stakeholders
to
two
available
CDROMS
with
implementation
information
(
prepared
jointly
by
EPA
and
Interior's
Office
of
Surface
Mining).
It
could
also
alert
stakeholders
to
the
Acid
Drainage
Technology
Initiative,
and
its
parent
organization,
The
International
Network
for
Acid
Prevention,
which
have
useful
resources
available,
some
of
which
are
included
in
the
public
record
for
this
planning
process.
Finally,
due
to
the
relatively
small
number
of
facilities
discharging
the
bulk
of
the
TWPE,
EPA
could
also
provide
assistance
to
permit
writers
in
preparing
BPJ­
based
permits.

Overview
This
report
presents
information
for
the
following
topics:
Background
Industry
and
Related
Subcategories
Wastewater
Characteristics
and
Pollutant
Sources
Pollutants
Discharged
Treatment
Technology
and
Pollution
Prevention
Concerns
Identified
Pre­
Proposal
FINAL
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Mining
August
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2004
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37
Concerns
Identified
in
Comments
to
Proposal
Followup
Contacts
Possible
Solutions
Attachments
provide
the
following
supporting
information:
EPA
Databases
and
References
Used
in
this
Review
Point
Source
Categories
Identified
Solely
Through
Factor
4
Guidelines
Applicability
and
Regulatory
History
PCS
Discharges
TRI
Discharges
Reported
Pollutant
Loadings
The
Occurence
of
Selenium
in
the
Upper
Kanawha
Formation
of
the
Pennsylvanian
System
in
the
Southern
West
Virginia
Coal
Fields
West
Virginia's
Manganese
Relief
Protocol
Background
In
preparation
for
proposing
the
Preliminary
Effluent
Guidelines
Program
Plan
for
2004/
2005
("
Preliminary
Plan,"
published
in
February
2004),
EPA
analyzed
four
factors
identified
in
the
draft
"
National
Strategy
for
Industrial
Clean
Water"(
Edocket
OW­
2003­
0074­
0215).
See
Attachment
A
for
more
background
about
the
304(
m)
planning
Process.
The
four
factors
focus
on:
1
Potential
impacts
to
human
health
and
the
environment.
Preliminary
results
are
summarized
in
the
"
Factor
1
Analysis:
Human
Health
and
Environmental
Impacts
 
Status
of
Screening
Level
Review
Phase"
(
Edocket
OW­
2003­
0074­
0410).
2
Identification
of
an
applicable
and
demonstrated
technology,
process
change,
or
pollution
prevention
alternative
that
can
effectively
reduce
pollutants
discharged.
Preliminary
results
are
summarized
in
the
"
Factor
2
Analysis:
Technology
Advances
and
Process
Changes
 
Status
of
Screening
Level
Review
Phase."
(
Edocket
OW­
2003­
0074­
0287).
3
Evaluation
of
the
cost,
performance,
and
affordability
of
the
technology,
process
change,
or
pollution
prevention
measures
identified
using
the
second
factor.
4
Implementation
and
efficiency
concerns.
Preliminary
results
are
presented
in
the
"
Factor
4
Analysis:
Implementation
and
Efficiency
Considerations
 
Status
of
Screening
Level
Review
Phase"
(
Edocket
OW­
2003­
0074­
0329)

When
all
of
the
results
were
integrated
prior
to
proposing
the
Preliminary
Plan,
EPA
determined
that
8
point
source
categories
with
existing
effluent
guidelines
had
been
identified
solely
through
Factor
4
concerns.
(
See
list
in
the
Attachment
B.)
In
order
to
determine
the
best
course
of
action
to
address
these
concerns,
EPA
performed
an
analysis
of
issues
and
potential
solutions
for
each
of
the
8
categories.
The
results
of
that
analysis
for
Coal
Mining
are
presented
in
this
report.
No
specific
subcategories
were
identified
during
the
Factor
4
analysis.
FINAL
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Coal
Mining
August
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2004
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37
Industry
and
Related
Subcategories
The
Coal
Mining
point
source
category
is
regulated
at
40
CFR
Part
434.
See
Attachment
C
for
the
applicability
and
regulatory
background.
This
point
source
category
includes
facilities
reporting
under
Standard
Industrial
Classification
(
SIC)
industry
group122,
Bituminous
Coal
And
Lignite
Mining.
Specifically,
it
includes
SIC
1221,
Bituminous
Coal
and
Lignite
Surface
Mining,
and
SIC
1222,
Bituminous
Coal
Underground
Mining.
No
specific
subcategories
were
identified
during
the
Factor
4
analysis.

°
SIC
1221
­
Bituminous
Coal
and
Lignite
Surface
Mining
Establishments
primarily
engaged
in
producing
bituminous
coal
or
lignite
at
surface
mines
or
in
developing
bituminous
coal
or
lignite
surface
mines.
This
industry
includes
auger
mining,
strip
mining,
culm
bank
mining,
and
other
surface
mining,
by
owners
or
lessees
or
by
establishments
which
have
complete
responsibility
for
operating
bituminous
coal
and
lignite
surface
mines
for
others
on
a
contract
or
fee
basis.
Bituminous
coal
and
lignite
preparation
plants
performing
such
activities
as
cleaning,
crushing,
screening
or
sizing
are
included
if
operated
in
conjunction
with
a
mine
site,
or
if
operated
independently
of
any
type
of
mine.

°
SIC
1222
­
Bituminous
Coal
Underground
Mining
Establishments
primarily
engaged
in
producing
bituminous
coal
in
underground
mines
or
in
developing
bituminous
coal
underground
mines.
This
industry
includes
underground
mining
by
owners
or
lessees
or
by
establishments
which
have
complete
responsibility
for
operating
bituminous
coal
underground
mines
for
others
on
a
contract
or
fee
basis.
Bituminous
coal
preparation
plants
performing
such
activities
as
cleaning,
crushing,
screening
or
sizing
are
included
if
operated
in
conjunction
with
a
mine.
Independent
bituminous
coal
preparation
plants
are
classified
in
Industry
1221.

°
SIC
code
1231
­
Anthracite
Mining
Establishments
primarily
engaged
in
producing
anthracite
or
in
developing
anthracite
mines.
All
establishments
in
the
United
States
that
are
classified
in
this
industry
are
located
in
Pennsylvania.
This
industry
includes
mining
by
owners
or
lessees
or
by
establishments
which
have
complete
responsibility
for
operating
anthracite
mines
for
others
on
a
contract
or
fee
basis.
Also
included
are
anthracite
preparation
plants,
whether
or
not
operated
in
conjunction
with
a
mine.

The
following
tables
present
the
facilities
in
this
category
that
report
to
the
Permit
Compliance
System
(
PCS)
and
to
the
Toxic
Release
Inventory
(
TRI).
(
Note:
Since
this
industry
ranked
low
during
the
screening
phase,
EPA
did
not
verify
any
of
the
information
reported
to
PCS
and
TRI,
and
has
used
it
as
reported.
Although
the
information
in
PCS
and
TRI
is
limited,
it
can
provide
insight
into
this
industry.
See
Attachment
A
for
more
details
about
PCS
and
TRI.)
Table
1
shows
the
number
of
facilities
identified
in
this
industry.
Table
2
lists
the
facilities
reporting
to
PCS
under
these
SIC
codes.
Table
3
lists
the
facilities
reporting
to
TRI
under
these
SIC
codes.
Attachments
D
and
E
list
these
facilities
along
with
their
reported
discharges.
FINAL
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Coal
Mining
August
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2004
Page
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Table
1.
Number
of
Facilities
SIC
1997
Census
PCS
TRI
Total
Major
Minor
Total
No
reported
discharge
Direct
discharge
Indirect
discharge
Both
direct
&
indirect
1221
829
129
15
114
50
33
17
0
0
1222
614
17
1
16
27
22
5
0
0
1231
68
0
0
0
0
0
0
0
0
Source:
PCSLoads2000,
TRIReleases2000
Table
2.
Coal
Mining
Facilities
Reporting
to
PCS,
Sorted
by
State
SIC
Facility
NPDES
ID
Facility
Name
Facility
City
&
State
1221
AL0021971
JIM
WALTER
RESOURCES
MINE
3
ADGER,
AL
1221
AL0026590
JIM
WALTER
RESOURCES
MINE
4
BROOKWOOD,
AL
1221
AL0062421
DRUMMOND
CO
INCORP
SHOAL
CREEK
ADGER,
AL
1221
AL0003620
US
STEEL
MIN
CO
LLC
CONCORD
PT
ADGER,
AL
1222
CO0027154
TWENTYMILE
COAL
COMPANY
OAK
CREEK,
CO
1221
MD0055182
METTIKI
COAL
LLC
(
also
reports
to
TRI)
OAKLAND,
MD
1221
MT0000892
DECKER
COAL
CO
(
WEST
MINE)
DECKER,
MT
1221
MT0024210
DECKER
COAL
CO
(
EAST
MINE)
DECKER,
MT
1221
UT0022918
CANYON
FUEL
CO.
LLC
­
SUFCO
MIDVALE,
UT
1221
WV0050717
UPSHUR
PROPERTY
INC.
BUCKHANNON,
WV
FINAL
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Coal
Mining
August
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2004
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Table
3.
Coal
Mining
Facilities
Reporting
to
TRI
SIC
Code
Facility
TRI
ID
Facility
Name
Facility
City
&
State
1222
35006SSTLM8800O
U.
S.
STEEL
MINING
CO.
L.
L.
C.
OAK
GROVE
SYS.
ADGER,
AL
1221
81625TRPPR65MIL
TRAPPER
MINING
INC.
CRAIG,
CO
1221
61440FRMNN1480E
FREEMAN
UNITED
COAL
MINING
CO.
INDUSTRY
MINE
INDUSTRY,
IL
1222
62634LKHRTELKHA
ELKHART
MINE
ELKHART,
IL
1221
47557PRDMN10471
PRIDE
MINE
S­
321
MONROE
CITY,
IN
1221
47601VGCLC3700N
VIGO
COAL
CO.
INC.
CYPRESS
CREEK
MINE
BOONVILLE,
IN
1222
21550MTTKC293TA
METTIKI
COAL
L.
L.
C.
OAKLAND,
MD
1221
43812XFRDM544CH
OXFORD
MINING
CO.
INC.
COSHOCTON,
OH
1222
43976HRRSN86395
HARRISON
PROCESSING
CORP.
HOPEDALE,
OH
1221
45634SNDSH38701
SANDS
HILL
COAL
CO.
INC.
HAMDEN,
OH
1221
26504PTRTM22MIL
PATRIOT
MINING
CO.
INC.
CROWN
MINE
STAR
CITY,
WV
1221
26504PTRTM12MIL
PATRIOT
MINING
CO.
INC.
METZ
MINE
STAR
CITY,
WV
1221
26504PTRTM12MIA
PATRIOT
MINING
CO.
INC.
DENTS
RUN
MINE
STAR
CITY,
WV
1221
26707BFFLCRTE9A
BUFFALO
COAL
CO.
INC.
PREP
PLANT
BAYARD,
WV
1221
26707BFFLCRTE90
BUFFALO
COAL
CO.
INC.
C­
1
BAYARD,
WV
1221
25507CTNRY5914C
CATENARY
COAL
CO.
ESKDALE,
WV
1221
25130HBTMNUSRT1
HOBET
MINING
INC.
MADISON,
WV
1221
24874KPLRPRTE97
KEPLER
PROCESSING
CO.
POCAHONTAS
NO
51
PREP
PLANT
PINEVILLE,
WV
1221
25019VNDLRCOUNT
VANDALIA
RESOURCES
INC.
BICKMORE,
WV
1221
25031PPLCHUSRTE
APPALACHIAN
MINING
INC.
BOOMER,
WV
1221
26206VRGRNRTE82
EVERGREEN
MINING
CO.
COWEN,
WV
1222
25193LKRNCPOBOX
ELK
RUN
COAL
CO.
CHESS
PREPARATION
PLANT
SYLVESTER,
WV
Of
the
31
facilities
reporting
water
discharges
to
PCS
or
TRI,
13
are
located
in
West
Virginia
and
three
are
located
nearby
in
eastern
Ohio.
Another
5
are
in
Alabama.
The
rest
are
located
primarily
in
the
midwest
and
west:
two
each
in
Indiana,
Illinois,
Montana
and
Colorado,
and
one
each
in
Maryland
and
Utah.
The
map
on
the
following
page
shows
the
locations
of
the
facilities
reporting
to
TRI
or
PCS.
FINAL
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Coal
Mining
August
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2004
Page
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37
U.
S.
Census
data
indicates
a
decrease
in
the
number
of
the
number
of
coal
mines
by
almost
40%
between
1992
and
1997.
Value
of
goods
shipped
has
also
declined
by
10%
or
more
for
bituminous
coal
during
the
same
time
period.
Anthracite
mining
showed
an
almost
14%
increase
in
value
of
goods
shipped.
See
Table
4
below.

In
addition
to
U.
S.
census
data,
statistics
for
the
coal
mining
industry
are
provided
by
the
U.
S.
Department
of
Labor
and
the
Energy
Information
Administration
(
EIA).
Table
5
presents
the
number
of
coal
operations
in
the
U.
S.
from
1997
to
2002,
generally
decreasing
by
around
20%.
Table
6
presents
coal
production
from
1996
to
2000,
which
remains
steady.

Table
4.
1992
and
1997
Census
Data
SIC
Sector
Number
of
Establishments
Value
of
Goods
Shipped
(
in
billions
of
dollars)

1997
1992
%
Change
1997
1992
%
Change
1221
Bituminous
coal
and
lignite
­
surface
829
1,359
­
39.0
12.5
13.8
­
9.9
1222
Bituminous
coal
­
underground
614
1,008
­
39.1
10.8
12.6
­
14.4
1231
Anthracite
mining
68
Na
Na
0.18
0.16
13.8
Source:
1997
U.
S.
Economic
Census
aN
indicates
that
comparable
data
were
not
available
Table
5.
U.
S.
Coal
Mining
Operations
from
1997
to
2002
Operations
1997
1998
1999
2000
2001
2002
%
Change
from
1997
to
2002
Underground
Mines
968
910
817
771
777
711
­
26.5
Surface
Mines
1,117
1,069
1,011
920
937
921
­
17.5
Preparation
Plants
432
422
399
363
354
355
­
17.8
Total
Mining
Operations
2,578
2,459
2,274
2,099
2,122
2,046
­
20.6
Source:
U.
S.
Department
of
Labor
FINAL
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Coal
Mining
August
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2004
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Table
6.
U.
S.
Coal
Production
from
1997
to
2000
(
in
millions
of
short
tons)

1996
1997
1998
1999
2000
Average
Annual
Percent
Change
(
1996­
2000)

Total
U.
S.
Production
1,064
1,090
1,118
1,100
1,074
0.20
Source:
EIA
web
page.

Wastewater
Characteristics
and
Pollutant
Sources
No
process
water
is
used
for
coal
extraction.
Wastewater
content
varies
according
to
mine
location,
soil
content,
and
purity
of
the
coal
extracted.
There
is
no
correlation
between
production
rate
and
wastewater
volume.
See
Table
7
below
for
facility
flow
information.

Table
7.
Wastewater
Flows
SIC
code
No.
of
Major
Facilities
Reporting
Nonzero
Flows
Median
Facility
Flow
2000
(
MG)
Range
of
Facility
Flows
2000
(
MG)
Total
Flow
2000
(
MG)

1221
9
831.21
63
­
6,914
15,676.75
1222
1
526.11
NA
526.11
Source:
PCSLoads2000.
NA
 
no
range
was
calculated;
only
one
facility
reported
a
nonzero
flow.

Common
sources
of
wastewater
in
the
coal
mining
industry
include
precipitation,
surface
runoff,
ground
water
infiltration,
and
coal
preparation
plant
effluent.
No
process
water
is
used
during
the
coal
mining
process.
Preparation
plants
use
water
for
washing
the
coal
to
remove
impurities.
Characteristics
of
different
classifications
of
coal
mine
wastewater
are
presented
in
Table
8.
FINAL
DRAFT
Coal
Mining
August
12,
2004
Page
9
of
37
Table
8.
Sources
of
Process
Wastewater
in
Coal
Mining
Wastewater
Source
Characteristics
acid
mine
drainage
suspended
solids,
low
pH,
high
concentrations
of
iron
and
other
metals
alkaline
mine
drainage
low
levels
of
suspended
solids,
neutral
or
slightly
high
pH,
low
concentrations
of
metals.

preparation
plants
high
levels
of
coal
fines.

reclamation
variable
levels
of
suspended
solids,
low
concentrations
of
iron
&
manganese.

Source:
Coal
Mining
Technical
Development
Document.

Pollutants
Discharged
Pollutant
discharges
as
reported
to
PCS
and
TRI
were
evaluated
as
part
of
the
Factor
1
Analysis:
Human
Health
and
Environmental
Impacts.
Pounds
reported
as
discharged
were
converted,
wherever
possible,
to
their
toxic
weighted
pound
equivalents
to
provide
a
sense
of
relative
hazard
associated
with
those
discharges.
(
Note:
indirect
discharge
amounts
reflect
reductions
that
are
expected
to
occur
at
the
receiving
treatment
facility.)
Both
TRI
and
PCS
contain
information
about
pollutants
discharged
by
coal
mining
facilities.
These
pollutants
can
be
characterized
as
nonconventional,
conventional,
or
priority
pollutants.

PCS:
Of
the
10
facilities
reporting
discharges
to
PCS,
one
company's
two
mines
in
a
single
town
in
Montana
contributes
73%
of
the
pounds
of
pollutants
discharged.
The
facility
in
Utah
generates
the
third
highest
pounds
discharged,
accounting
for
an
additional
21%.
When
looking
at
toxic
weighted
discharges,
a
single
facility
in
Alabama
contributes
over
40%
of
the
toxic
weighted
pound
equivalents
(
TWPE)
discharged,
and
when
these
discharges
are
combined
with
other
facilities
also
located
in
this
town,
62%
of
the
PCS
TWPE
are
accounted
for.
Over
95%
of
the
TWPE
discharges
reported
to
PCS
originate
from
6
facilities
(
the
three
Alabama
discharges
and
those
of
three
other
facilities)
contribute.

TRI:
Of
the
22
facilities
reporting
to
TRI,
one
company's
two
operations
in
a
single
town
in
West
Virginia
contributes
70%
of
the
pounds
discharged.
Discharges
from
West
Virginia
alone
account
for
98%
of
all
discharged
pounds
reported
to
TRI.
When
looking
at
toxic
weighted
discharges,
8
facilities
contribute
over
95%
of
the
TWPE.
Of
these,
a
single
facility
with
three
mines
in
the
same
town
contribute
almost
50%
of
the
TWPE
reported
to
TRI.

Overall:
Of
the
31
facilities
reporting
to
PCS
and
TRI
(
one
facility
reports
to
both
databases),
one
company's
two
mines
in
a
single
town
in
Montana
contributes
72%
of
the
total
pounds
of
pollutants
discharged.
Discharges
from
the
facility
in
Utah
contribute
an
additional
21%.
Together,
these
three
facilities
account
for
93%
of
the
pounds
reported
discharged
by
this
industry.
When
looking
at
toxic
FINAL
DRAFT
Coal
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August
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2004
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37
weighted
discharges,
46%
of
the
TWPE
discharged
comes
from
one
company's
three
mines
in
a
single
West
Virginia
town
and
52%
come
from
discharges
in
the
state
as
a
whole.
An
additional
34%
of
the
TWPE
discharged
comes
from
Ohio.
There
is
a
clear
regional
concentration
of
TWPE
discharges,
with
94%
of
all
TWPE
discharged
by
facilities
in
the
adjacent
states
of
West
Virginia,
Ohio,
Indiana,
and
Illinois.
Arranged
by
EPA
Region,
52%
of
the
TWPE
is
discharged
in
Region
III
and
42%
of
the
TWPE
is
discharged
in
Region
V.

Discharged
pollutants
that
can
be
characterized
as
nonconventional,
conventional,
or
priority
pollutants.
Table
9
below
shows
the
relative
contributions
of
each
pollutant
type.
See
Attachment
D
for
the
discharges
in
toxic
weighted
pounds
as
reported
to
PCS
by
facility
and
see
Attachment
E
for
the
discharges
in
toxic
weighted
pounds
as
reported
to
TRI
by
facility.
See
Attachment
F
for
a
breakout
of
these
discharges
by
pollutant.
A
discussion
of
each
pollutant
type
discharged
follows
the
table.

Table
9.
Pollutant
Discharges
Reported
to
PCS
and
TRI
Pollutant
Category
&
Primary
Pollutants
PCS
LBS
PCS
TWPE
TRI
LBS
(
Direct
Only)
TRI
TWPE
(
Direct
Only)
All
Pollutants
33,529,627
1,385
741,083
22,472
Nonconventional
31,563,104
1,380
739,958
2,245
Total
Dissolved
Solids
(
TDS)
31,471,976
n/
a
 
 
Manganese
11,621
818
(
59%)
16,400
1,155
(
51%)
Iron
7,742
434
(
31%)
 
 
Ammonia
as
Nitrogen
 
 
723,229
1,089
(
49%)
Conventional
1,966,515
0
0
0
Total
Suspended
Solids
(
TSS)
1,966,357
 
 
 
BOD
96
 
 
 
Oil
and
Grease
62
 
 
 
Priority
8*
5*
1,125
20,227
Mercury
 
 
149
17,444
(
86%)
Arsenic
 
 
769
2,668
(
13%)
*
Copper
discharge.
FINAL
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August
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2004
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Nonconventional
Pollutants
About
94%
of
all
the
pounds
reported
discharged
for
this
industry
are
nonconventional
pollutants.
Of
these,
total
dissolved
solids
comprise
92%
of
the
total
pounds.
However,
a
toxic
weight
is
not
available
for
this
pollutant
parameter.
For
both
PCS
and
TRI
discharges,
manganese
contributes
over
50%
of
the
toxic
weighted
pound
equivalents
(
TWPE)
discharged.
The
remainder
of
the
TWPE
discharged
are
iron
discharges
in
PCS
and
ammonia
as
nitrogen
discharges
in
TRI.

Conventional
Pollutants
Conventional
pollutants
comprise
about
6%
of
the
total
pounds
reported
as
discharged.
Over
99%
of
the
pounds
of
conventional
pollutants
reported
to
PCS
are
total
suspended
solids.
Again,
toxic
weights
are
not
available
for
this
pollutant
parameter.
No
information
on
conventional
pollutants
is
available
through
TRI.

Priority
Pollutants
Priority
pollutants
contribute
the
smallest
portion
of
total
pounds
discharged
(
less
than
1%)
but
contribute
the
largest
quantity
of
TWPE
discharged
by
this
industry.
Of
the
TWPE
discharges,
86%
are
due
to
reported
mercury
discharges
reported
to
TRI.
Another
13%
are
due
to
arsenic
discharges,
also
reported
to
TRI.
The
only
priority
pollutant
discharge
reported
to
PCS
is
copper.

For
purposes
of
comparison,
the
toxic
weighted
pound
equivalents
(
TWPE)
for
Coal
Mining
are
presented
in
the
following
tables
along
with
the
industries
reporting
the
highest
discharges
in
each
database.
Table
10
presents
the
information
reported
to
PCS
and
Table
11
presents
the
information
reported
to
TRI.
For
a
description
of
the
derivation
of
the
values
in
these
tables,
see
the
memo
in
the
public
record
titled
"
Description
and
Results
of
EPA
Methodology
to
Synthesize
Screening
Level
Results
for
the
Effluent
Guidelines
Program
Plan
for
2004/
2005,"
which
is
available
through
Edocket
at
document
number
OW­
2003­
0074­
0391.

Table
10.
Coal
Mining
TWPE
Reported
to
PCS
Compared
to
Top
Ranking
Results
40
CFR
Part
Point
Source
Category
PCS
Reported
TWPE
PCS
Rank
423
Steam
electric
power
generation
2,933,209
1
414
Organic
chemicals,
plastics
and
synthetic
fibers
1,805,928
2
422
Phosphate
manufacturing
1,095,321
3
415
Inorganic
chemicals
manufacturing
853,568
4
421
Nonferrous
metals
manufacturing
434,925
5
440
Ore
mining
and
dressing
383,560
6
40
CFR
Part
Point
Source
Category
PCS
Reported
TWPE
PCS
Rank
FINAL
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Coal
Mining
August
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2004
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37
410
Textile
mills
296,601
7
419
Petroleum
refining
198,251
8
455
Pesticide
chemicals
manufacturing,
formulating
178,977
9
418
Fertilizer
manufacturing
116,464
10
434
Coal
Mining
1,385
32
Table
11.
Coal
Mining
TWPE
Reported
to
TRI
Compared
to
Top
Ranking
Results
40
CFR
Part
Point
Source
Category
TRI
Reported
TWPE
TRI
Rank
414
Organic
chemicals,
plastics
and
synthetic
fibers
7,303,782
1
423
Steam
electric
power
generation
1,856,645
2
421
Nonferrous
metals
manufacturing
978,450
3
430
Pulp,
paper
and
paperboard
(
Phase
II)
628,785
4
415
Inorganic
chemicals
manufacturing
624,250
5
429
Timber
products
processing
404,926
6
419
Petroleum
refining
385,347
7
455
Pesticide
chemicals
manufacturing,
formulating
324,393
8
428
Rubber
manufacturing
166,343
9
463
Plastic
molding
and
forming
106,189
10
434
Coal
Mining
22,472
21
FINAL
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Coal
Mining
August
12,
2004
Page
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37
Treatment
Technology
and
Pollution
Prevention
Acid
discharges:
Mines
with
acid
discharges
treat
wastewater
using
chemical
precipitation,
pH
adjustment,
aeration,
and
settling.
Neutralization
and
aeration
promote
oxidation
of
metals
such
as
iron
and
magnesium.
The
metal
ions
form
insoluble
metal
hydroxides,
which
precipitate
out
of
solution
and
may
be
removed
by
settling.
Acid
mine
drainage
is
caused
by
the
oxidation
of
pyrite,
which
release
iron,
sulfide,
and
hydrogen
ions
into
surface
waters.
In
some
locations,
manganese
also
may
be
released.
The
rate
of
acid
formation
is
dependent
on
the
amount
of
pyrite
in
overburden,
the
presence
of
limestone
or
other
neutralizers;
and
exposure
to
air
containing
the
oxygen
necessary
for
oxidation.
Special
handling
techniques
and
water
management
may
be
applied
to
reduce
acid
mine
drainage.
Special
handling
techniques
include
identifying
potentially
acid
rock
prior
to
placement;
and
strategically
locating
potentially
acid
materials
to
minimize
exposure
to
water
and
air.
Water
management
techniques
include
1)
installing
high
wall
drainage
systems
to
promote
surface
runoff
and
reduce
contact
between
water
and
the
spoil
surface;
2)
installing
spoil
drains
to
minimize
contact
time
between
groundwater
and
mine
spoil;
3)
filling
trenches
with
alkaline
material
to
lower
the
rate
of
acid
formation;
and
4)
flooding
acidforming
materials
to
avoid
air
contact.

Alkaline
discharges:
Some
mines
with
alkaline
discharges
use
settling
ponds
to
remove
suspended
solids
from
wastewater.

Preparation
plants:
These
plants
use
a
slurry
treatment
system,
consisting
of
a
settling
basin
or
clarifier
and
thickeners,
to
treat
the
coal
wash
water.
Runoff
from
surrounding
areas
is
treated
in
a
settling
pond.

Reclamation
areas:
Such
areas
use
sedimentation
ponds
to
remove
solids
from
wastewater.

Concerns
Identified
Pre­
Proposal
The
Coal
Mining
point
source
category
was
identified
by
several
responders
surveyed
by
the
Agency
in
the
process
of
preparing
the
2004/
2005
Plan.
Their
suggestions
are
summarized
below.

Comments
on
the
2002/
2003
Plan
(
Section
2.3
of
the
"
Factor
4
Analysis:
Implementation
and
Efficiency
Considerations
 
Status
of
Screening
Level
Review
Phase"
(
Edocket
OW­
2003­
0074­
0329)
A
commenter
asserted
that
the
effluent
guidelines
for
the
coal
mining
point
source
category
require
revision
because
rainfall
exemptions
for
coal
mining
in
the
current
effluent
guidelines
allow
for
relaxation
of
limits
as
soon
as
it
rains.
Furthermore,
the
commenter
stated
that
settlement
basins
used
as
primary
control
for
mine
drainage
do
not
work
very
well
when
it
rains.
No
supporting
information
was
provided.
In
its
August,
2002
response
to
comments,
the
Agency
noted
that
it
intended
to
fully
consider
coal
mining
operations
when
it
develops
future
304(
m)
plans.
(
Note:
The
Engineering
and
Analysis
Division
recently
revised
these
effluent
guidelines,
with
revisions
promulgated
in
January
of
2002;
however,
the
revised
rule
did
not
reassess
the
effluent
limitations
for
precipitation
events.)

Previous
Suggestions
(
Section
2.4
of
the
"
Factor
4
Analysis")
FINAL
DRAFT
Coal
Mining
August
12,
2004
Page
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37
Although
responders
recommended
coal
mining
for
revised
effluent
guidelines
development,
no
specific
concerns
were
noted.

AMSA
&
ASIWPCA
(
Section
2.6
of
the
"
Factor
4
Analysis")
A
stakeholder
noted
that
Coal
Mining
operations
discharge
manganese,
which
is
generating
problems,
notably
in
West
Virginia
streams.
Follow­
up
discussion
with
this
stakeholder
during
the
detailed
investigation
phase
explained
that
manganese
in
coal
mining
effluent
does
not
necessarily
adversely
effect
the
receiving
stream
as
much
as
the
discharge
stream
remaining
after
treatment
to
remove
manganese,
which
consists
basically
of
increasing
the
pH.
(
The
water
quality
standard
for
manganese
is
based
on
concerns
for
staining
relative
to
drinking
water
uses.)
The
effluent
then
must
be
neutralized
before
discharging,
and
options
typically
include
adding
either
acid
or
aluminum
to
the
effluent
to
precipitate
the
manganese.
(
Another
side
effect
of
changing
the
pH
is
the
potential
increase
in
concentration
of
the
more
toxic
selenium
in
the
effluent,
since
it
can
more
readily
leach
into
the
water
from
the
pit
cleanings.
See
Attachment
G.)

Concerns
Identified
in
Comments
to
Proposal
No
concerns
for
the
Coal
Mining
point
source
category
were
received
in
comments
to
the
Preliminary
Plan.

Followup
Contacts
The
following
contacts
identified
initial
concerns
and
provided
followup
information
for
this
category:
Bill
Telliard,
EPA/
OST/
EAD
(
202)
566­
1061
Dan
Sweeney,
EPA
Region
3,
(
215)
814­
5731
Connie
Kagey,
EPA
Region
4,
(
404)
562­
9300
Andrea
Zimmer,
EPA
Region
4,
(
404)
562­
9306
David
Vande
Linde,
West
Virginia
DEP,
(
304)
759­
0510
Possible
Solutions
EPA
appreciates
all
comments
and
suggestions
provided
by
the
stakeholders
and
EPA
Regional
staff.
Based
on
information
reported
to
TRI
and
PCS,
toxic
discharges
from
coal
mining
operations
are
low
relative
to
other
industrial
categories.
In
addition,
a
few
facilities
generally
drive
the
toxic
weighted
pound
equivalents
(
TWPE)
for
this
industry.
The
pollutants
driving
the
TWPE
estimate
for
these
few
facilities
are
mercury
and
arsenic.
Stakeholders
and
EPA
staff
identified
various
issues
associated
with
discharges
from
coal
mining
operations.
The
information
in
the
record
at
this
time
does
not
support
the
concerns
raised.
As
with
any
comments
received
by
the
Agency,
EPA
can
not
address
these
suggestions
without
adequate
supporting
data.
In
the
event
that
stakeholders
provide
additional
data
and
supporting
information,
on
these
or
any
of
the
issues
identified
above,
EPA
will
reevaluate
them
at
that
time.
In
the
FINAL
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Coal
Mining
August
12,
2004
Page
15
of
37
absence
of
revisions
to
the
effluent
guidelines,
these
concerns
could
be
addressed
through
improved
information
dissemination
and
outreach
by
EPA.

Stormwater
concerns:
Stormwater
issues
could
be
addressed
through
the
development
and
distribution
of
a
guidance
document
on
the
topic.
In
fact,
such
guidance
was
promised
in
the
final
1985
regulation
for
coal
mining
(
at
50
FR
41301,
published
on
October
9,
1985).
However,
for
purposes
of
the
coal
mining
effluent
guidelines,
all
water
that
falls
on
a
mining
site
is
considered
process
water
and
should
be
treated
as
such.
Stormwater
was
specifically
considered
during
the
development
of
the
Western
Mining
regulations,
and
is
part
of
the
modeling
described
for
calculating
total
discharge.
EPA
has
prepared
two
CD­
ROMs
in
coordination
with
the
Department
of
Interior's
Office
of
Surface
Mining
(
OSM)
provides
information
on
all
the
BMPs
and
the
other
provides
formulas
for
determining
baseline
performance
and
calculating
limits,
including
the
stormwater
loadings
for
the
western
mining
category.

High
discharges
of
TDS
and
TSS:
Pollutants
TDS
and
TSS
do
not
have
toxic
weighting
factors,
so
discharges
of
these
substances
cannot
be
assessed
in
terms
of
potential
risk.
However,
EPA
has
prepared
two
CD­
ROMs
in
coordination
with
the
Department
of
Interior's
Office
of
Surface
Mining.
One
provides
information
on
all
the
BMPs
and
the
other
provides
formulas
for
determining
baseline
performance
and
calculating
limits.
(
Note:
Although
discharges
of
TDS
and
TSS
are
frequently
the
result
of
stormwater
runoff,
no
one
identified
concerns
specifically
associated
with
these
types
of
discharges.)

Manganese
concerns:
Manganese
was
included
in
the
guidelines
because
it
was
historically
a
parameter
indicating
acid
mine
drainage,
and
is
easy
to
measure.
In
addition,
the
treatment
to
remove
manganese
ensured
that
other
metals
present
in
wastewater
would
be
removed
during
the
process.
During
postmining
activities,
these
concerns
could
be
addressed
through
the
use
of
a
sampling
protocol
to
determine
whether
manganese
discharges
were
in
fact
adversely
impacting
the
receiving
stream.
Such
a
protocol
would
be
used
to
determine
eligibility
for
manganese
limit
modifications
to
an
NPDES
permit
for
water
quality
limits
only.
An
example
protocol
was
provided
by
David
Vande
Linde
of
West
Virginia,
where
it
was
in
use
until
the
state
adopted
a
water
quality
standard
for
manganese,
and
can
be
found
at
Attachment
H.
However,
since
manganese
is
limited
through
the
ELG,
the
only
way
to
waive
monitoring
of
this
pollutant
is
to
demonstrate
that
it
is
not
present.

Additional
Issues:
During
followup
discussions,
the
need
to
consider
far­
field
effects
was
raised
(
downstream
impacts
of
coal
mine
discharges).
Guidance
could
provide
assistance
for
addressing
farfield
effects
which
are
not
generally
considered.
It
could
also
identify
resources
available
to
permit
writers,
including
the
data
collection
requirements
provided
through
the
Office
of
Surface
Mining
and
the
guidance
manuals
developed
by
the
Acid
Drainage
Technology
Initiative
of
the
International
Network
for
Acid
Prevention
(
INAP).

Two
supporting
documents
published
by
the
National
Mine
Land
Reclamation
Center
at
West
Virginia
University
will
be
included
in
the
public
record
for
this
planning
process:
1)
Prediction
of
Water
Quality
at
Surface
Mines,
prepared
by
members
of
the
Prediction
Workgroup
of
the
Acid
Drainage
Technology
Initiative
(
ADTI),
and
2)
A
Handbook
of
Technologies
for
Avoidance
and
Remediation
of
Acid
Mine
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Drainage
prepared
by
J.
Skousen,
A.
Rose,
G.
Geidel,
J.
Foreman,
R.
Evans,
W.
Hellier,
and
members
of
the
Avoidance
and
Remediation
Working
Group
of
the
Acid
Drainage
Technology
Initiative
(
ADTI).
An
additional
resource
that
is
available
but
not
included
in
the
public
record
is
Acid
Mine
Drainage
Control
&
Treatment,
second
edition,
compiled
by
Jeffrey
Skousen
and
Paul
Ziemkiewicz,
and
also
available
through
the
National
Mine
Land
Reclamation
Center
at
West
Virginia
University.

Summary
of
Potential
Solutions:
Concerns
identified
for
this
industry
could
be
addressed
through
improved
information
dissemination
and
outreach
by
EPA.
The
Agency
could
prepare
a
fact
sheet
with
answers
to
frequently
asked
questions
(
FAQs)
and
post
it
on
its
web
site.
In
addition,
the
Agency
could
announce
the
availability
of
this
fact
sheet,
the
CD­
ROMS
of
implementation
information,
and
the
name
of
the
Engineering
and
Analysis
Division
(
EAD)
staff
available
to
answer
questions.
Finally,
it
could
disseminate
useful
information
developed
by
the
Acid
Drainage
Technology
Initiative,
and
its
parent
organization,
The
International
Network
for
Acid
Prevention.
These
announcements
could
be
made
at
the
regular
meetings
for
permit
writers
and
pretreatment
coordinators
held
by
the
Office
of
Wastewater
Management
(
OWM)
and
also
through
email
alerts
to
the
EAD
stakeholders
mailing
list.
Finally,
due
to
the
relatively
small
number
of
facilities
discharging
the
bulk
of
the
TWPE,
EPA
could
also
provide
assistance
to
permit
writers
in
preparing
BPJ­
based
permits.
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Attachment
A
EPA
Databases
and
References
Used
in
this
Review
Overview
of
the
304(
m)
Planning
Process
CWA
Section
304(
m)(
1)
requires
EPA
to
establish
a
schedule
for
the
annual
review
and
revision
of
all
existing
effluent
guidelines
and
to
identify
categories
of
point
sources
discharging
toxic
or
non­
conventional
pollutants
for
which
EPA
has
not
published
effluent
guidelines.
To
accomplish
this
review,
EPA
conducted
a
screening­
level
analysis
using
readily
available
information
from
EPA's
Permit
Compliance
System
(
PCS)
and
Toxics
Release
Inventory
(
TRI)
databases.
EPA
estimated
the
mass
of
pollutants
discharged
from
each
category,
weighted
the
pollutant
releases
based
on
chemical
toxicity,
and
ranked
the
categories
based
on
the
toxicweighted
pollutant
releases.

In
addition
to
reported
discharges
in
PCS
and
TRI,
EPA
used
other
readily
available
data,
as
well
as
information
from
public
outreach,
including
industry
categories
recommended
by
stakeholders
for
regulatory
development
or
regulatory
revision,
to
evaluate
implementation
and
efficiency
considerations.

For
additional
details
on
EPA's
screening­
level
analysis
refer
the
following
documents
in
EPA
Docket
Number
OW­
2003­
0074:


Memorandum:
Description
and
Results
of
EPA
Methodology
to
Synthesize
Screening
Level
Results
for
the
Effluent
Guidelines
Program
Plan
for
2004/
2005,
DCN
548,
Section
3.0;


Development
of
PCSLoads
2000,
DCN
620,
Section
2.1.2
(
this
document
explains
how
pollutant
loads
were
calculated
from
PCS
data);
and

Evaluation
of
RSEI
Model
Runs,
DCN
618,
Section
2.1.1.

Information
from
EPA's
Permit
Compliance
System
(
PCS)
and
Toxics
Release
Inventory
(
TRI)
databases
were
used
to
create
the
PCSLoads2000
and
TRIReleases2000
databases.
These
databases
were
the
primary
source
of
information
used
to
conduct
this
review.
Since
this
industry
ranked
low
during
the
screening
phase,
however,
EPA
did
not
verify
any
of
the
information
reported
to
PCS
and
TRI,
and
has
used
it
as
reported.

TRIReleases2000
The
Toxic
Release
Inventory
(
TRI)
is
the
major
source
of
data
for
the
TRIReleases2000
database.
TRI
is
the
common
name
for
Section
313
of
the
Emergency
Planning
and
Community
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Right­
to­
Know
Act
(
EPCRA).
Each
year,
facilities
that
meet
certain
thresholds
must
report
their
releases
and
other
waste
management
activities
for
listed
toxic
chemicals.
That
is,
facilities
must
report
the
quantities
of
toxic
chemicals
recycled,
collected
and
combusted
for
energy
recovery,
treated
for
destruction,
or
disposed
of.
A
separate
report
must
be
filed
for
each
chemical
that
exceeds
the
reporting
threshold.
The
TRI
list
of
chemicals
for
reporting
year
2000
includes
more
than
600
chemicals
and
chemical
categories.
For
this
review,
EPA
used
data
for
reporting
year
2000,
because
they
were
the
most
recent
available
at
the
time
the
review
began.

There
are
three
criteria
that
a
facility
must
meet
to
be
required
to
submit
a
TRI
report
for
that
reporting
year.
The
criteria
are:

(
1)
SIC
Code
Determination:
Facilities
in
SIC
Codes
20
through
39,
seven
additional
SIC
codes
outside
this
range,
and
federal
facilities
must
concern
themselves
with
TRI
reporting.
EPA
rarely
checks
or
refutes
facility
claims
regarding
the
SIC
code
identification.
The
primary
SIC
code
determines
TRI
reporting.

(
2)
Number
of
Employees:
Facilities
must
have
10
or
more
full­
time
employees
or
their
equivalent.
EPA
defines
a
"
full­
time
equivalent"
as
a
person
that
works
2,000
hours
in
the
reporting
year
(
there
are
several
exceptions
and
special
circumstances
that
are
well­
defined
in
the
TRI
reporting
instructions).

(
3)
Activity
Thresholds:
If
the
facility
is
in
a
covered
SIC
code
and
has
10
or
more
full­
time
employee
equivalents
it
must
conduct
an
activity
threshold
analysis
for
every
chemical
and
chemical
category
on
the
current
TRI
list.
The
facility
must
determine
whether
it
manufactures,
processes,
OR
otherwise
uses
each
chemical
at
or
above
the
appropriate
activity
threshold.
Reporting
thresholds
are
not
based
on
the
amount
of
release.
All
TRI
thresholds
are
based
on
mass,
not
concentration.
Different
thresholds
apply
for
persistent
bioaccumulative
toxic
(
PBT)
chemicals
than
for
non­
PBT
chemicals.

In
TRI,
facilities
report
annual
loads
released
to
the
environment
of
each
toxic
chemical
or
chemical
category
that
meets
reporting
requirements.
They
must
report
onsite
releases
to
air,
receiving
streams,
disposal
to
land,
underground
wells,
and
several
other
categories.
They
must
also
report
the
amount
of
toxic
chemicals
in
wastes
transferred
to
off­
site
locations,
including
discharges
to
POTWs
and
other
off­
site
locations,
such
as
commercial
waste
disposal
facilities.

For
this
review,
EPA
focused
on
the
amount
of
chemicals
facilities
reported
either
discharging
directly
to
a
receiving
stream
or
transferring
to
a
POTW.
For
facilities
discharging
directly
to
a
stream,
the
loads
were
taken
directly
from
the
reported
TRI
data
for
calendar
year
2000.
For
facilities
that
transfer
toxic
chemicals
to
POTWs,
EPA
first
adjusted
the
TRI
pollutant
loads
reported
to
be
transferred
to
POTWs
to
account
for
pollutant
removal
that
occurs
at
the
POTW
prior
to
discharge
to
the
receiving
stream.
This
adjustment
was
made
using
POTW
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removal
efficiencies
from
EPA's
Risk
Screening
Environmental
Indicators
(
RSEI)
model
(
see
Section
2.1.1
of
the
docket
for
more
information
on
TRI
and
the
RSEI
model).

Reporting
facilities
are
not
required
to
sample
and
analyze
wastestreams
to
determine
the
quantities
of
toxic
chemicals
released.
They
may
estimate
releases
based
on
mass
balance
calculations,
published
emission
factors,
site­
specific
emission
factors,
or
other
approaches.
Facilities
are
required
to
indicate,
by
a
reporting
code,
the
basis
of
their
release
estimate.
TRI's
reporting
guidance
is
that
for
chemicals
reasonably
expected
to
be
present
but
measured
below
the
detection
limit,
facilities
should
use
one
half
the
detection
limit
to
estimate
the
mass
released.
The
guidance
is
slightly
different
for
dioxins
and
dioxin­
like
compounds
in
that
it
allows
nondetects
to
be
treated
as
zero.

TRI
provides
the
option
for
facilities
to
report
releases
as
specific
numbers
or
as
ranges,
if
appropriate.
Specific
estimates
are
encouraged
if
data
are
available
to
ensure
the
accuracy;
however,
EPA
allows
facilities
to
report
releases
in
the
following
ranges:
1
to
10
pounds,
11
to
499
pounds,
and
500
to
999
pounds.
For
this
analysis,
EPA
used
the
mid­
point
of
each
reported
range
to
represent
a
facility's
releases.

EPA
weighted
the
direct
and
indirect
pollutant
releases
to
surface
waters
using
toxic
weighting
factors
(
TWFs)
developed
by
Office
of
Water/
Engineering
and
Analysis
Division
(
EAD),
to
calculate
toxic
weighted
pound
equivalents
(
TWPE)
for
each
reported
release.
See
4.2.3
and
4.2.4
for
more
discussion
of
TWFs
and
calculation
of
TWPE.
EPA
compiled
data
taken
from
TRI,
the
adjusted
releases
from
POTWs
to
surface
waters,
the
calculated
TWPE,
and
the
relationship
between
SIC
codes
and
point
source
category
into
a
Microsoft
Access
 
database
named
TRIReleases2000.
Some
corrections
were
made
to
this
database
as
further
study
was
conducted
on
the
TRI
data.
Limitations
of
TRI
are
discussed
in
Section
IV
of
the
Technical
Support
Document
for
this
planning
process.

PCSLoads2000
The
Permit
Compliance
System
(
PCS)
is
the
major
source
of
data
for
the
PCSLoads2000
database.
PCS
is
a
computerized
management
information
system
maintained
by
EPA's
Office
of
Enforcement
and
Compliance
Assurance
(
OECA).
It
was
created
to
track
permit,
compliance,
and
enforcement
status
of
facilities
regulated
by
the
National
Pollutant
Discharge
Elimination
System
(
NPDES)
program
under
the
Clean
Water
Act
(
CWA).

More
than
65,000
industrial
facilities
and
water
treatment
plants
have
obtained
permits
for
water
discharges
of
regulated
pollutants.
To
provide
an
initial
framework
for
setting
permit
issuance
priorities,
EPA
developed
a
major/
minor
classification
system
for
industrial
and
municipal
wastewater
discharges.
Major
discharges
almost
always
have
the
capability
to
impact
receiving
waters
if
not
controlled
and,
therefore,
have
been
accorded
more
regulatory
attention
than
minor
discharges.
There
are
approximately
6,400
facilities
(
including
sewerage
systems)
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with
major
discharges
for
which
PCS
has
extensive
records.
Permitting
authorities
classify
discharges
as
major
based
on
an
assessment
of
six
characteristics:

(
1)
toxic
pollutant
potential;
(
2)
ratio
of
discharge
flow
to
stream
flow;
(
3)
conventional
pollutant
loading;
(
4)
public
health
impact;
(
5)
water
quality
factors;
and
(
6)
proximity
to
coastal
waters.

Facilities
with
major
discharges
must
report
compliance
with
NPDES
permit
limits
via
monthly
Discharge
Monitoring
Reports
(
DMRs)
submitted
to
the
permitting
authority.
The
permitting
authority
enters
the
reported
DMR
data
into
PCS,
including
the
type
of
violation
(
if
any),
concentration
and
quantity
values,
and
the
Quarterly
Non­
Compliance
Report
(
QNCR)
indicators.
Minor
discharges
may,
or
may
not,
adversely
impact
receiving
water
if
not
controlled.
Therefore,
EPA
does
not
require
DMRs
for
facilities
with
minor
discharges.
For
this
reason,
the
PCS
database
includes
data
only
for
a
limited
set
of
minor
dischargers
when
the
states
choose
to
include
these
data.
As
a
consequence,
extensive
data
are
not
available
for
minor
discharges
in
PCS.

Parameters
in
PCS
include
water
quality
parameters
(
such
as
pH
and
temperature),
specific
chemicals,
bulk
parameters
(
such
as
BOD
5
and
TSS),
and
flow
rates.
Although
other
pollutants
may
be
discharged,
PCS
only
contains
data
for
the
parameters
identified
in
the
facility's
NPDES
permit.
Facilities
typically
report
monthly
average
pounds
per
day
discharged,
but
also
report
daily
maxima,
and
pollutant
concentrations.

For
this
review,
EPA
used
data
for
reporting
year
2000,
to
correspond
to
the
data
obtained
from
TRI.
EPA
used
its
Effluent
Data
Statistics
(
EDS)
system
program
to
calculate
annual
pollutant
discharges
using
the
monthly
reports
in
PCS.
Because
units
of
measure
vary
widely
in
PCS,
EPA
developed
the
EDS
system
to
estimate
mass
loadings
based
on
data
stored
in
PCS.
The
EDS
system
uses
existing
PCS
reported
mass
loading
values
or
multiplies
reported
discharge
flows
and
effluent
concentrations
to
estimate
loadings
for
each
outfall
(
discharge
pipe),
taking
into
account
the
various
units
of
concentration
and
flow
rates.

Where
concentrations
were
reported
as
below
detection
limit
(
BDL)
EPA
assumed
the
parameter
concentration
was
equal
to
zero
for
parameters
never
detected
by
the
facility
in
2000.
For
parameters
sometimes
detected
and
sometimes
not,
the
"
BDL"
concentration
was
set
equal
to
half
of
the
detection
limit.
.
The
EDS
system
program
sums
the
monthly
loads
to
calculate
annual
discharges,
interpolating
(
using
average
reported
loads)
for
months
with
missing
reports.

EPA
weighted
the
calculated
annual
pollutant
discharges
using
EAD's
TWFs
to
calculate
TWPE
for
each
reported
discharge,
as
it
did
for
the
reported
TRI
releases.
See
sections
4.2.3
and
4.2.4
for
more
discussion
of
TWFs
and
calculation
of
TWPE.
EPA
compiled
data
taken
from
FINAL
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Coal
Mining
August
12,
2004
Page
21
of
37
PCS,
the
calculated
TWPE,
and
the
relationship
between
SIC
codes
and
point
source
category
into
a
Microsoft
Access
 
database
named
PCSLoads2000.
As
further
study
was
conducted
on
the
PCS
data,
some
corrections
were
made.

Other
Information
Sources
In
addition
to
TRI
and
PCS,
EPA
used
the
following
sources
of
information
in
its
review
of
this
industry:


1997
Economic
Census
data.


Contacts
with
reporting
facilities
to
verify
reported
releases
and
facility
categorization.


US
EPA,
1981.
Development
Document
for
Effluent
Limitations
Guidelines
and
Standards
for
the
Coal
Mining
Point
Source
Category.
440181057b.


Pennsylvania
Department
of
Environmental
Protection,
1998.
Coal
mine
drainage
prediction
and
pollution
prevention
in
Pennsylvania.
PA
DEP,
Harrisburg,
PA.


US
Census
Bureau.
Comparative
Statistics
for
the
United
States.
Accessed
at
<
http://
www.
census.
gov>
on
June
28,
2004.


U.
S.
Department
of
Labor
web
page.
Accessed
at
<
http://
www.
msha.
gov/
ACCINJ/
BOTHCL.
HTM
>
on
July
2,
2004.


Energy
Information
Administration
(
EIA)
web
page.
Accessed
at
<
http://
www.
eia.
doe.
gov/
cneaf/
coal/
cia/
html/
t1p01p1.
html
>
on
July
2,
2004.
FINAL
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Mining
August
12,
2004
Page
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37
Attachment
B
Point
Source
Categories
Identified
Solely
Through
Factor
4
Industry
Formal
Comment
Process
Previous
Suggestions
(
Sec.
2.4)
Draft
Strategy
Outreach
Comments
on
Draft
Strategy
(
Sec.
2.2)
Comments
on
2002/
2003
Plan
(
Sec.
2.3)
Permitting
Authorities
(
Sec.
2.5)
AMSA
&
ASIWPCA
(
Sec.
2.6)

Coal
Mining



Coil
Coating

Dairy
Products
Processing

Electrical
and
Electronic
Components

Fruits
and
Vegetable
Processing


Metal
Molding
and
Casting




Mineral
Mining
and
Processing

Seafood
Processing



FINAL
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Mining
August
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2004
Page
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37
Attachment
C
Guidelines
Applicability
and
Regulatory
History
Applicability
of
40
CFR
Part
434
Subpart
A
 
General
Provisions.
This
part
applies
to
discharges
from
any
coal
mine
at
which
the
extraction
of
coal
is
taking
place
or
is
planned
to
be
undertaken
and
to
coal
preparation
plants
and
associated
areas.

Subpart
B
 
Coal
Preparation
Plants
and
Coal
Preparation
Plant
Associated
Areas.
The
provisions
of
this
subpart
are
applicable
to
discharges
from
coal
preparation
plants
and
coal
preparation
plant
association
areas,
as
indicated,
including
discharges
which
are
pumped,
siphoned,
or
drained
from
the
coal
preparation
plant
water
circuit
and
coal
storage,
refuse
storage,
and
ancillary
areas
related
to
the
cleaning
or
beneficiation
of
coal
of
any
rank
including,
but
not
limited
to,
bituminous,
lignite,
and
anthracite.

Subpart
C
 
Acid
or
Ferruginous
Mine
Drainage.
The
provisions
of
this
subpart
are
applicable
to
acid
or
ferruginous
mine
drainage
from
an
active
mining
area
resulting
from
the
mining
of
coal
of
any
rank
including,
but
not
limited
to,
bituminous,
lignite,
and
anthracite.

Subpart
D
 
Alkaline
Mine
Drainage.
The
provisions
of
this
subpart
are
applicable
to
alkaline
mine
drainage
from
an
active
mining
area
resulting
from
the
mining
of
coal
of
any
rank
including,
but
not
limited
to,
bituminous,
lignite,
and
anthracite.

Subpart
E
 
Post­
Mining
Areas.
The
provisions
of
this
subpart
are
applicable
to
discharges
from
post­
mining
areas,
except
as
provided
in
subpart
H
 
Western
Alkaline
Coal
Mining
of
this
part.

Subpart
F
 
Miscellaneous
Provisions.
The
provisions
of
this
subpart
F
apply
to
this
part
434
as
specified
in
subparts
B,
C,
D,
E
and
G
of
this
part.

Subpart
G
 
Coal
Remining
(
a)
This
subpart
applies
to
pre­
existing
discharges
that
are
located
within
or
are
hydrologically
connected
to
pollution
abatement
areas
of
a
coal
remining
operation.

(
b)
A
pre­
existing
discharge
that
is
intercepted
by
active
mining
or
that
is
commingled
with
waste
streams
from
active
mining
areas
for
treatment
is
subject
to
the
provisions
of
Subpart
F,
§
434.61,
"
commingling
of
waste
streams."
For
the
purposes
of
this
subpart,
§
434.61
requires
compliance
with
applicable
BPT,
BAT,
BCT,
and
NSPS
effluent
limitations
in
subparts
C,
D,
and
F
of
this
part.
Section
434.61
applies
to
the
commingled
waste
stream
only
during
the
time
when
the
preexisting
discharge
is
intercepted
by
active
mining
or
is
commingled
with
active
mine
wastewater
for
treatment
or
discharge.
After
commingling
has
ceased,
the
pre­
existing
discharge
is
subject
to
the
provisions
of
this
part.
FINAL
DRAFT
Coal
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August
12,
2004
Page
24
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37
(
c)
In
situations
where
coal
remining
operations
seek
reissuance
of
an
existing
remining
permit
with
BPJ
limitations
and
the
regulatory
authority
determines
that
it
is
not
feasible
for
a
remining
operator
to
re­
establish
baseline
pollutant
levels
in
accordance
with
the
statistical
procedures
contained
in
Appendix
B
of
this
part,
pre­
existing
discharge
limitations
at
existing
remining
operations
shall
remain
subject
to
baseline
pollutant
levels
established
during
the
original
permit
application.

(
d)
The
effluent
limitations
in
this
subpart
apply
to
pre­
existing
discharges
until
the
appropriate
SMCRA
authority
has
authorized
bond
release.

Subpart
H
 
Western
Alkaline
Coal
Mining
(
a)
This
subpart
applies
to
alkaline
mine
drainage
at
western
coal
mining
operations
from
reclamation
areas,
brushing
and
grubbing
areas,
topsoil
stockpiling
areas,
and
regraded
areas.

(
b)
This
subpart
applies
to
drainage
at
western
coal
mining
operations
from
reclamation
areas,
brushing
and
grubbing
areas,
topsoil
stockpiling
areas,
and
regraded
areas
where
the
discharge,
before
any
treatment,
meets
all
the
following
requirements:
(
1)
pH
is
equal
to
or
greater
than
6.0;
(
2)
Dissolved
iron
concentration
is
less
than
10
mg/
L;
and
(
3)
Net
alkalinity
is
greater
than
zero.

(
c)
The
effluent
limitations
in
this
subpart
apply
until
the
appropriate
SMCRA
authority
has
authorized
bond
release.

REGULATORY
BACKGROUND
Regulatory
History
°
BPT
limitations
for
Subparts
B
(
preparation
plants),
C
(
acid
drainage
mines),
and
D
(
alkaline
drainage
mines)
were
first
promulgated
on
April
26,
1977.

°
NSPS
were
promulgated
for
Subparts
B,
C,
and
D
on
January
12,
1979,
and
subcategories
for
reclamation
and
western
mines
were
established.

°
EPA
revised
BPT
and
NSPS
rainfall
exemptions
on
December
28,
1979.

°
Proposed
BAT
and
NSPS
limitations
for
all
subcategories
were
published
in
January
1981
including
proposed
amendments
to
BPT.

°
The
technology
basis
of
existing
regulations
was
neutralization
and
settling.
FINAL
DRAFT
Coal
Mining
August
12,
2004
Page
25
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37
Existing
Limitations
Limits
for
BAT
are
the
same
as
BPT
limits.
NSPS
is
identical
to
BAT,
except
NSPS
require
no
discharge
of
wastewater
pollutants
from
preparation
plants
(
Subpart
B).
The
technology
basis
for
the
no
discharge
requirement
was
a
complete
water
recycle
system.

No
limits
were
proposed
for
Subpart
H
(
Western
Mines).
Operators
are
required
to
submit
and
implement
a
Sediment
Control
Plan
to
maintain
sediment
discharges
at
or
below
pre­
mining
levels.

Table
C­
1.
Effluent
Guidelines
for
Coal
Mining
Part
434
BPT
­
30­
day
averages
(
mg/
L)
BPT
­
daily
maximum
(
mg/
L)

TSS
35
70
Settleable
Solidsa
0.5
mL/
L
pH
within
range
of
6
to
9
within
range
of
6
to
9
Iron,
Total
3.5
7.0
Manganese,
Totalb
2.0
4.0
Source:
Coal
Mining
TDD
aLimits
for
settleable
solids
only
apply
to
Subpart
E
(
post
mining
areas).
bNo
manganese
limits
exist
for
Subpart
D
(
alkaline
drainage
mines).

°
Subpart
F,
Miscellaneous
Provisions,
contains
alternative
limirations
that
apply
during
precipitation
events.
The
limitations
in
Table
C­
2
apply
to
discharges
that
result
from
a
rainfall
or
snowmelt
event
less
than
the
10­
year,
24­
hour
design
storm.
For
events
greater
than
the
10
year,
24­
hour
precipitation
event,
there
are
no
limitations
on
settleable
solids.
The
only
limitation
is
that
pH
remain
between
6
and
9.

Table
C­
2
Catastrophic
Precipitation
Event
Exemption
Pollutant
Parameter
BPT
­
daily
maximum
Settleable
Solidsa
0.5
mL/
L
pH
within
range
of
6
to
9
Source:
Coal
Mining
Technical
Development
Document
a
No
limits
on
settleable
solids
when
precipitation
exceeds
the
the
10
year,
24­
hour
storm.
FINAL
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Mining
August
12,
2004
Page
26
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37
Other
Regulations
In
addition
to
regulating
wastewater
discharges,
EPA
regulates
hazardous
and
solid
waste
under
the
Resource
Conservation
and
Recovery
Act
(
RCRA)
and
air
emissions
under
the
Clean
Air
Act
(
CAA).
Other
regulating
authorities
include:

°
Department
of
Labor,
Mine
Safety
and
Health
Administration
(
MSHA):
Responsible
for
all
federally
required
plans,
approvals,
certifications,
and
liscensing
relating
to
mine
safety.

°
Department
of
Interior,
Office
of
Surface
Mining
(
OSM):
Regulates
active
coal
mining
operations
and
supports
the
reclamation
of
abandoned
mines
as
required
by
the
Surface
Mining
Control
and
Reclamation
Act
of
1977
(
SMCRA).

°
Army
Corps
of
Engineers
(
COE):
Responsible
for
processing
permit
applications
and
issuing
permits
as
outlined
in
Section
404
of
the
CWA.
FINAL
DRAFT
Coal
Mining
August
12,
2004
Page
27
of
37
Attachment
D
PCS
Discharges
SIC
NPDES
ID
NAME
CITY
Flow
(
MGD)
LBS/
YR1
TWPE1
Percent
of
Total
SIC
TWPE1
Cumulative
%
of
Total
SIC
TWPE1
1221
AL0021971
JIM
WALTER
RESOURCES
MINE
3
ADGER
2
627,443
588
44%
44%

1221
AL0026590
JIM
WALTER
RESOURCES
MINE
4
BROOKWOOD
9
504,807
278
21%
65%

1221
AL0062421
DRUMMOND
CO
INCORP
SHOAL
CREEK
ADGER
19
528,932
219
16%
81%

1221
WV0050717
UPSHUR
PROPERTY
INC.
BUCKHANNON
1
19,751
167
12%
94%

1221
AL0003620
US
STEEL
MIN
CO
LLC
CONCORD
PT
ADGER
5
259,923
45
3%
97%

1221
MD0055182
METTIKI
COAL
LLC
OAKLAND
0
1,078
19
1221
MT0000892
DECKER
COAL
CO
(
WEST
MINE)
DECKER
2
8,990,509
9
1221
UT0022918
CANYON
FUEL
CO.
LLC
­
SUFCO
MIDVALE
3
7,041,007
8
1221
MT0024210
DECKER
COAL
CO
(
EAST
MINE)
DECKER
2
15,542,295
4
1221
TOTAL
43
33,515,744
1,336
1222
CO0027154
TWENTYMILE
COAL
COMPANY
OAK
CREEK
1
13,893
49
100%
100%

1222
TOTAL
1
13,893
49
Total
for
Both
SICs
33,529,637
1,385
FINAL
DRAFT
Coal
Mining
August
12,
2004
Page
28
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37
Attachment
E
TRI
Discharges
­
Only
Direct
Discharges
Reported
SIC
Code
Facility
TRI
ID
Facility
Name
Facility
City
Facility
State
Total
lbs
Total
TWPE
Percent
Total
of
SIC
TWPE
Cumulative
Percent
Total
of
SIC
TWPE
1221
26504PTRTM22MIL
PATRIOT
MINING
CO.
INC.
CROWN
MINE
STAR
CITY
WV
871
5,912
163%
163%

1221
43812XFRDM544CH
OXFORD
MINING
CO.
INC.
COSHOCTON
OH
39
4,566
126%
289%

1221
26504PTRTM12MIL
PATRIOT
MINING
CO.
INC.
METZ
MINE
STAR
CITY
WV
25
2,927
81%
369%

1221
26504PTRTM12MIA
PATRIOT
MINING
CO.
INC.
DENTS
RUN
MINE
STAR
CITY
WV
1,739
2,240
62%
431%

1221
47557PRDMN10471
PRIDE
MINE
S­
321
MONROE
CITY
IN
3,137
1,185
33%
464%

1221
26707BFFLCRTE9A
BUFFALO
COAL
CO.
INC.
PREP
PLANT
BAYARD
WV
456,558
687
19%
483%

1221
61440FRMNN1480E
FREEMAN
UNITED
COAL
MINING
CO.

INDUSTRY
MINE
INDUSTRY
IL
9,550
673
19%
501%

1221
26707BFFLCRTE90
BUFFALO
COAL
CO.
INC.
C­
1
BAYARD
WV
61,204
92
3%
504%

1221
25507CTNRY5914C
CATENARY
COAL
CO.
ESKDALE
WV
59,856
90
2%
506%

1221
81625TRPPR65MIL
TRAPPER
MINING
INC.
CRAIG
CO
204
80
2%
508%

1221
25130HBTMNUSRT1
HOBET
MINING
INC.
MADISON
WV
51,626
78
2%
511%

1221
24874KPLRPRTE97
KEPLER
PROCESSING
CO.
POCAHONTAS
NO
51
PREP
PLANT
PINEVILLE
WV
42,748
64
2%
512%

1221
47601VGCLC3700N
VIGO
COAL
CO.
INC.
CYPRESS
CREEK
MINE
BOONVILLE
IN
313
40
1%
513%

1221
25019VNDLRCOUNT
VANDALIA
RESOURCES
INC.
BICKMORE
WV
15,430
23
1%
514%

1221
25031PPLCHUSRTE
APPALACHIAN
MINING
INC.
BOOMER
WV
10,350
16
0%
514%

1221
45634SNDSH38701
SANDS
HILL
COAL
CO.
INC.
HAMDEN
OH
1,500
2
0%
515%

1221
26206VRGRNRTE82
EVERGREEN
MINING
CO.
COWEN
WV
102
0
0%
515%

1221
TOTAL
715,252
18,675
1222
43976HRRSN86395
HARRISON
PROCESSING
CORP.
HOPEDALE
OH
33
3,630
16%
16%

1222
21550MTTKC293TA
METTIKI
COAL
L.
L.
C.
OAKLAND
MD
1,520
103
0%
17%

1222
25193LKRNCPOBOX
ELK
RUN
COAL
CO.
CHESS
PREPARATION
PLANT
SYLVESTER
WV
23,855
36
0%
17%

1222
35006SSTLM8800O
U.
S.
STEEL
MINING
CO.
L.
L.
C.
OAK
GROVE
SYS.
ADGER
AL
379
22
0%
17%

1222
62634LKHRTELKHA
ELKHART
MINE
ELKHART
IL
44
6
0%
17%

1222
TOTAL
25,831
3,796
Total
for
Both
SICs
741,083
22,472
FINAL
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Mining
August
12,
2004
Page
29
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37
FINAL
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Mining
August
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2004
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37
Attachment
F
Reported
Pollutant
Loadings
SIC
Pollutant
Name
CAS
Poll
Grp
Code
PCS
Discharges
TRI
Direct
Discharges
No.
Facils
Reporting
Pollutant
Pounds
TWPE
No.
Facils
Reporting
Pollutant
Pounds
TWPE
SIC
1221
1221
BOD
5­
DAY
(
CARBONACEOUS)
C003
CP
4
96
1221
OIL
AND
GREASE
C035
CP
7
62
1221
TOTAL
SUSPENDED
SOLIDS
C009
CP
14
1,953,532
1221
SUM
OF
CONVENTIONAL
POLLUTANTS
1,953,690
0
0
0
1221
COBALT
7440484
NC
1
1
0.1
1221
AMMONIA
AS
NITROGEN
7664417
NC
9
699,374
1,053
1221
MANGANESE
7439965
NC
6
11,034
777
6
14,823
1,044
1221
BARIUM
7440393
NC
1
37
0.1
1221
CHLORIDE
16887006
NC
1
2
0.000044
1221
CHLORINE,
TOTAL
RESIDUAL
7782505
NC
1
5
2
1221
ALUMINUM
7429905
NC
1
1,952
126
1221
IRON
7439896
NC
13
76,968
431
1221
TOTAL
KJELDAHL
NITROGEN
C021
NC
1
107
1221
TOTAL
DISSOLVED
SOLIDS
C010
NC
4
31,471,976
1221
SUM
OF
NONCONVENTIONAL
POLLUTANTS
31,562,044
1,336
714,235
2,097
1221
LEAD
7439921
PP
1
28
63
1221
CHROMIUM
7440473
PP
2
34
17
1221
ARSENIC
7440382
PP
2
769
2,668
1221
COPPER
7440508
PP
2
18
11
1221
NICKEL
7440020
PP
2
28
3
1221
ZINC
7440666
PP
1
22
1
1221
MERCURY
7439976
PP
4
118
13,815
1221
SUM
OF
PRIORITY
POLLUTANTS
0
0
1,017
16,578
SIC
Pollutant
Name
CAS
Poll
Grp
Code
PCS
Discharges
TRI
Direct
Discharges
No.
Facils
Reporting
Pollutant
Pounds
TWPE
No.
Facils
Reporting
Pollutant
Pounds
TWPE
FINAL
DRAFT
Coal
Mining
August
12,
2004
Page
31
of
37
SIC
1222
1222
TOTAL
SUSPENDED
SOLIDS
C009
CP
1
12,825
1222
SUM
OF
CONVENTIONAL
POLLUTANTS
12,825
0
0
0
1222
AMMONIA
AS
NITROGEN
7664417
NC
1
23,855
36
1222
BARIUM
7440393
NC
2
291
1
1222
IRON
7439896
NC
1
474
3
1222
MANGANESE
7439965
NC
1
587
41
4
1,577
111
1222
SUM
OF
NONCONVENTIONAL
POLLUTANTS
1,060
44
25,723
148
1222
ZINC
7440666
PP
2
38
2
1222
CHROMIUM
7440473
PP
2
33
17
1222
COPPER
7440508
PP
1
8
5
1222
MERCURY
7439976
PP
1
31
3,629
1222
NICKEL
7440020
PP
1
6
1
1222
SUM
OF
PRIORITY
POLLUTANTS
8
5
108
3,649
FINAL
DRAFT
Coal
Mining
August
12,
2004
Page
32
of
37
Attachment
G
THE
OCCURRENCE
OF
SELENIUM
IN
THE
UPPER
KANAWHA
FORMATION
OF
THE
PENNSYLVANIAN
SYSTEM
IN
THE
SOUTHERN
WEST
VIRGINIA
COAL
FIELDS
ABSTRACT
An
exhaustive
search
of
the
literature
on
selenium
reveals
that
there
are
little
or
no
studies
available
on
the
concentrations
of
selenium
in
rock
overburden
anywhere
in
the
United
States.
The
Environmental
Protection
Agency's
(
EPA)
concern
with
the
instream
concentrations
of
selenium
in
the
Draft
Programmatic
Environmental
Impact
Statement
conducted
in
6
watersheds
in
West
Virginia
for
mountaintop
mining,
brought
the
lack
of
data
on
selenium
to
the
attention
of
West
Virginia's
Department
of
Environmental
Protection
(
DEP).
To
acquire
data
for
a
mining
National
Pollution
Discharge
Elimination
System
Permit
(
NPDES),
the
DEP's
Water
Resource
section
required
the
drilling
of
holes
to
secure
data
on
selenium
in
the
overburden
of
selected
surface
mine
permits.
The
results,
procedures
and
conclusions
drawn
from
the
initial
drilling
under
this
requirement
are
presented
in
this
paper.

DISCUSSION
The
EPA
conducted
extensive
water
testing
in
6
watersheds
in
West
Virginia
in
conjunction
with
the
mountaintop
mining
EIS.
This
study
was
started
in
1999
and
a
draft
report
on
findings
is
available.
In
addition
to
the
typical
metals
that
are
analyzed
for
in
a
surface
mine
(
SMCRA)
permit,
selenium
was
noted
as
a
trace
metal
of
concern
by
the
EPA.
This
concern
arose
from
selenium
concentrations
in
excess
of
the
5
ppb
instream
chronic
water
quality
limit
that
exists
in
West
Virginia.
Because
the
EIS
study
purposely
picked
areas
that
were/
are
being
surface
mined
in
the
state,
the
conclusion
has
been
drawn
that
surface
mining
areas,
particularly
valley
fills,
are
contributing
to
the
selenium
concentrations
noted.
A
literature
search
on
selenium
revealed
that
extensive
research
on
selenium
in
fly
ash
(
Lemly)
and
soils
(
Vance)
were
available,
but
no
papers
or
research
was
noted
on
the
concentrations
of
selenium
in
rock
overburden.
This
was
important
to
the
WVDEP,
because
we
needed
to
know
where
the
selenium
was
concentrated
on
a
surface
mine
job
to
suggest
ways
to
handle
overburden
or
use
other
techniques
to
mine
the
coal
without
harming
the
aquatic
environment
with
toxic
selenium,
which
can
cause
harm
to
fish
tissue,
animals
etc.
through
bio­
concentration.
A
study
by
the
West
Virginia
Geologic
Survey
(
WVGS)
was
posted
on
the
internet
that
indicated
that
coal
seams
of
the
Upper
Kanawha
Formation
of
the
Pennsylvanian
System
was
much
higher
in
selenium
than
other
strata
in
the
coal
areas
of
the
Appalachians.
This
study
was
done
by
measuring
the
trace
metals
in
the
fly
ash
of
the
coal
seams
that
were
burned
in
the
state,
and
back
calculating
the
amount
of
selenium
in
the
total
coal
seam.
The
WVGS
study,
and
other
research
reviewed,
plus
conversations
with
analytical
laboratory
personnel,
indicated
that
the
selenium
was
associated
with
organic/
carbon
based
material,
like
coal
seams,
carbonaceous
shale,
etc.
Previous
work
on
coal
ash
and
associated
materials
by
one
of
the
authors
of
this
paper
for
various
coal
companies
also
indicated
that
the
coal
seams
and
associated
"
pit
cleanings"
(
carbonaceous
roof,
floor
and
parting
material)
held
the
highest
concentrations
of
selenium
in
the
overburden.
If
the
vertical
location
of
the
selenium
in
the
"
pit
cleanings"
was
correct,
then
it
was
possible
to
design
a
materials
handling
plan
to
isolate
this
material
that
would
be
not
cost
prohibitive
in
the
mining
sequence.

PROTOCOL
USED
TO
ACQUIRE
AND
ANALYZE
THE
OVERBURDEN
SAMPLES
FOR
SELENIUM
FINAL
DRAFT
Coal
Mining
August
12,
2004
Page
33
of
37
2.
Since
1999,
the
WVDEP
has
required
all
of
the
baseline
water
sites
that
are
submitted
for
a
surface
mine
permit
to
be
tested
for
trace
metals
and
other
compounds,
such
as
phenols,
on
a
one
time
basis.
This
data,
plus
data
from
several
other
sources
(
1.)
NPDES
renewal
Table
IV­
C
analyses.
(
2.)
Data
from
the
Federal
Office
of
Surface
Mining
(
OSM)
trend
sites.
(
3)
Data
from
the
EIS
in
certain
watersheds.
(
4)
Data
from
Water
Resources
for
TMDL's
(
Total
Maximum
Daily
Loads)
etc.,
is
evaluated
for
selenium
and
other
trace
metal
concentrations
to
see
if
a
problem
exists.(
5)
Check
the
latest
303(
d)
impaired
streams
list
from
the
Division
of
water
Resources.
Any
area
that
has
had
previous
mining
and
reflects
over
5
ppb
selenium
(
current
instream
chronic
water
quality
standard
for
selenium)
will
be
selected
for
drilling
to
sample
the
overburden.
4.
The
drilling
will
be
on
approximately
2000'
spacing,
or
other
spacing
required
by
the
geologist
reviewing
the
surface
mining
(
SMCRA)
permit.
The
holes
will
be
located
on
the
tops
of
the
ridges
and
drill
down
to
10'
below
the
lowest
seam
to
be
mined.
This
will
insure
that
all
the
overburden
to
be
removed
is
covered
in
it's
entirety.
6.
The
core
from
the
drilling
will
be
broken
down
into
vertical
sections
of
5'
or
less
if
the
strata
type
changes.
The
object
is
to
break
the
core
down
into
small
recognizable
sections
that
can
be
separated
by
high
selenium
content
in
the
mining
sequence.
8.
Each
5'
or
less
section
is
then
analyzed
for
total
selenium
by
the
3050B
(
for
Acid
digestion
of
Solis)
method.
This
method
uses
a
graphite
furnace
that
can
detect
selenium
to
a
Minimum
Detection
Limit
of
1
ppb.
Any
strata
that
has
a
total
selenium
concentration
of
1mg/
kg
is
considered
potentially
toxic
and
will
have
to
undergo
an
additional
leachate
test.
10.
There
are
several
leachate
tests
available
for
the
next
level.
They
are
(
1)
Column
Leaching
(
2)
Soxhlet
(
3)
Phosphate
etc.
Any
leachate
test
that
results
in
a
reading
of
greater
that
5
ug/
kg
will
be
considered
toxic
for
selenium
and
will
be
included
in
a
specific
materials
handling
plan.

RESULTS
FROM
DRILLING
IN
LOGAN
AND
MINGO
COUNTIES
IN
SOUTHERN
WEST
VIRGINIA
The
protocol
was
applied
to
3
mining
areas
in
the
spring
of
2004.
The
results
of
1
hole
from
northern
Logan
County,
5
holes
from
southern
Logan
County
and
1
hole
from
Mingo
County
are
included
in
this
paper.
The
cross
section
of
the
Phoenix
#
4
area
in
southern
Logan
County
and
the
drill
logs
with
selenium
content
in
the
other
two
areas
indicate
that
the
selenium
is
concentrated
in
the
"
pit
cleanings"
as
theorized
at
the
beginning
of
the
study.
The
potentially
toxic
selenium
concentrations
of
1mg/
kg
are
almost
solely
concentrated
in
the
coal
seams,
partings
and
roof
and
floor
of
the
seams
to
be
mined.
The
leachate
tests
on
these
holes
are
in
progress
and
the
subject
of
a
followup
paper.
The
current
results
definitively
indicate
that
the
selenium
has
an
affinity
for
organic
material
in
the
overburden
column.

RECOMMENDED
MATERIALS
HANDLING
PLAN
2.
Because
the
toxic
selenium
material
that
needs
to
be
isolated
is
concentrated
in
small
vertical
zones
that
have
to
be
set
aside
to
recover
the
coal
seam,
and
the
material
is
a
black/
dark
gray
material
that
is
visibly
differentiated
in
the
field,
the
mining
company
can
split
this
material
out
in
the
coal
pits.
(
see
figure
__).
FINAL
DRAFT
Coal
Mining
August
12,
2004
Page
34
of
37
4.
It
is
important
to
rip
up
6"
to
1'
of
the
floor
of
the
bottom
coal
seam
so
that
no
selenium
laden
material
is
left
to
contaminate
the
water/
rock
interface.
6.
The
toxic
material
should
be
removed
to
an
area
on
the
job
that
is
high
and
dry
away
from
water
course,
and
under
no
circumstance
should
any
of
this
material
be
put
in
a
valley
fill.
8.
The
material
should
then
be
put
on
a
free
draining
pad
of
@
10'
of
coarse
non­
selenium
laden
material
and
covered
with
at
least
4'
of
the
most
impervious
material
on
the
surface
mine
job.
This
method
will
keep
water
from
leaching
through
the
selenium
laden
overburden.

CONCLUSIONS
It
is
apparent
from
the
analytical
results
to
date
that
the
selenium
is
concentrated
in
the
"
pit
cleanings".
The
cut­
off
of
1mg/
kg
limit
for
identifying
the
material
that
has
to
undergo
further
leachate
testing
looks
valid
in
differentiating
the
high
selenium
material
to
be
isolated
from
the
lower
concentration
material.
The
visual
difference
of
the
black
/
darker
selenium
laden
material
from
the
other
overburden
in
the
Upper
Kanawha
series
is
very
useful
in
separating
the
toxic
material
from
the
non­
toxic
in
the
field.
Further
work
needs
to
be
done
on
the
different
methods
of
leachate
tests
to
calculate
what
percentage
of
selenium
in
the
overburden
will
be
mobilized
into
the
hydrologic
environment.
The
moral
to
the
story
is
to
isolate
the
black/
darker
selenium
laden
material
and
to
keep
any
of
this
material
from
the
valley
fills.
This
material
,
besides
having
high
concentrations
of
selenium,
is
also
typically
high
in
iron
and
manganese
and
other
trace
metals,
as
well
as
more
acidic,
so
that
the
materials
handling
plan
suggested
will
pay
extra
dividends.
FINAL
DRAFT
Coal
Mining
August
12,
2004
Page
35
of
37
Attachment
H
WEST
VIRGINIA's
MANGANESE
RELIEF
PROTOCOL
June
5,
1997
I.
Eligibility.
With
the
goal
of
optimizing
conditions
for
aquatic
life
at
certain
mine
sites,
the
following
protocol
is
suggested
for
determining
eligibility
for
manganese
(
Mn)
limit
modifications
to
an
NPDES
permit.
Be
aware,
that
existing
guidelines
addressing
alkaline
mine
drainage
and
post
mining
are
still
in
effect.
Therefore,
please
consult
with
your
regional
NPDES
permit
writer
as
to
which
set
of
guidelines
best
serve
your
situation.
Furthermore,
regular
meetings
shall
be
held
with
the
regional
permit
writer
throughout
this
process
(
see
attached
flow
chart).

A.
Required
Outlet
Status.
These
modifications
will
be
granted
only
to
post
mining
sites:
surface
mines,
refuse
areas,
loadouts.
Post
mining
deep
mine
discharges
are
not
eligible,
as
per
40
CFR
434.

B.
Intake
Water
Testing.
Testing
will
be
done
on
six
(
6)
months
of
raw
intake
water
that
will
establish
a
representative
sample
and
a
median
Mn
level
that
is
to
be
used
as
a
benchmark
for
any
additional
tests.
After
the
median
Mn
level
is
established
a
fairly
large
sample
must
be
collected
of
the
intake
with
the
Mn
at
or
above
the
median
level.
The
large
sample
will
then
be
used
to
do
a
variety
of
treatability
and
toxicity
testing
at
various
pH
levels.
If
the
effluent
is
shown
to
remain
toxic
despite
Mn
relief
the
application
will
be
denied
so
further
testing
would
be
useless.
If
at
the
elevated
levels
of
Mn
are
not
shown
to
be
toxic
then
temporary
Mn
relief
could
be
granted
while
further
studies
are
conducted
on
the
benthics
of
the
receiving
stream.
Details
of
the
requirements
of
each
type
of
testing
are
shown
below.

1.
A
raw
water
study
of
six
(
6)
monthly
samples
must
be
completed
to
determine
the
characteristics
of
a
representative
sample.
Samples
are
to
be
taken
monthly
and
consecutively
until
six
(
6)
samples
have
been
obtained.
"
No
Flows"
are
not
to
be
counted
as
samples.
The
median
of
these
samples
shall
be
calculated
for
the
Mn
concentration.
(
All
future
tests
dealing
with
intake
water
for
the
treatability
and
toxic
screening
shall
be
done
on
a
sample
with
a
Mn
concentration
equal
to
or
greater
than
the
median
level.)
The
initial
samples
are
to
be
analyzed
for
the
following
parameters:
(
a)
Manganese
(
b)
Conductivity
(
c)
Hardness
(
d)
Acidity
(
e)
Alkalinity
(
f)
Iron
(
Fe)
(
g)
Aluminum
(
Al)
FINAL
DRAFT
Coal
Mining
August
12,
2004
Page
36
of
37
2.
Intake
water,
at
median
or
above
Mn
levels,
shall
then
be
analyzed
for
eligibity
by
performing
Treatability
Tests
at
the
pHs
of
6.0,
7.5,
and
9.0.
The
chemical
reagent
used
for
pH
adjustment
must
be
the
same
reagent
that
is
used
on
site.
The
following
parameters
will
be
determined
at
each
pH
level
with
"
Total"
and
"
Disolved"
metals
both
being
performed
only
on
the
"
Raw
Water",
and
"
Dissolved"
metals
only
will
be
performed
on
the
pH
adjusted
waters:

(
a)
Manganese
(
b)
Conductivity
(
c)
Hardness
(
d)
Acidity
(
e)
Alkalinity
(
f)
Iron
(
Fe)
(
g)
Aluminum
(
Al)
(
h)
Un­
ionized
Ammonia
(
where
anhydrous
ammonia
is
used
as
a
reagent)

3.
Intake
water,
at
the
adjusted
pH
levels:
6.0,
7.5,
9.0,
(
and
the
upper
pH
variance
limit
in
the
permit
if
it
is
greater
than
9.0),
shall
then
have
a
24
hour
toxic
screening
performed
on
it.
If
this
toxic
screening
and/
or
other
factors
indicate
that
the
effluent
will
remain
toxic
despite
Mn
relief,
further
testing
is
superfluous.

4.
If
the
toxic
screening
is
positive
a
preliminary
Benthic
Study
shall
be
conducted
at
this
time
to
establish
a
base
line
for
invertebrate
aquatic
life.
All
benthic
studies
are
to
be
conducted
in
at
least
two
(
2)
sites
to
provide,
as
much
as
possible,
a
control
representing
the
unaffected
portion
of
the
stream
prior
to
the
discharge
point.
Each
site
shall
be
evaluated
with
the
reasonable
goal
of
habitat
and
aquatic
life
improvement.

II.
Permit
Modification.
If
results
of
the
Eligibility
Tests
and
Toxic
Screening
so
indicate,
the
next
step
is
to
submit
your
test
data
with
a
letter
requesting
a
compliance
schedule
for
testing
of
the
outlet.
Each
site
is
to
be
judged
on
a
case­
by­
case
basis.
While
unfavorable
results
from
the
Eligibility
Tests
and
Toxic
Screening
would
preclude
modifying
the
permit
for
Mn,
favorable
results
do
not
mandate
such
modification.
All
other
factors
are
to
be
considered
by
the
Agency,
including
Title
46,
Series
1
Legislative
Rules.

A.
Compliance
Schedule
will
be
issued
with
a
ninety
(
90)
day
time
frame
with
the
following
conditions.

1.
pH
limits
of
6.0
­
9.0
will
be
maintained.

2.
Manganese
limits
will
be
"
Report
Only".

3.
Bioassay
(
toxicity
testing)
on
the
discharge.
(
a)
All
sampling
and
testing
performed
at
this
stage
must
be
done
during
typical
"
base
flow"
conditions.
FINAL
DRAFT
Coal
Mining
August
12,
2004
Page
37
of
37
(
b)
Bioassay
tests
shall
be
performed
in
accordance
with
EPA/
600/
4­
90/
027F.

B.
Modification.
Should
the
results
of
the
bioassay
indicate
that
the
effluent
is
toxic
to
aquatic
life,
the
permit
shall
remain
as
it
was
prior
to
the
compliance
schedule
being
granted.
Otherwise,
the
permit
will
be
modified
again
with
a
three
(
3)­
year
Compliance
Schedule.

1.
If
discharge
point
under
study
has
a
pH
variance
it
will
be
revoked
and
pH
limits
will
be
modified
to
6.0
through
9.0.

2.
Manganese
will
be
modified
to
"
Report
Only".

3.
Semi­
annual
benthic
monitoring
on
the
receiving
stream.
(
a)
At
a
minimum,
one
benthic
survey
station
will
be
established
downstream
of
the
discharge
point.
(
b)
Benthic
surveys
shall
be
conducted
according
to
EPA
No.
444/
4­
89­
001
May
1989.

NOTE:
Further
toxicity
testing
studies
may
be
needed
on
a
case­
by­
case
basis.
All
tests
must
be
performed
by
laboratories
certified
in
the
testing
procedure
involved.

All
sampling
locations
must
be
mutually
agreed
upon
by
the
permittee
and
WVDEP
personnel.
