  SEQ CHAPTER \h \r 1 

	

Project No.: 0172.04.005.422

	

DISTRIBUTION

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Project Name: 304m – Coal Mining Detailed Study

	

TELEPHONE CALL RECORD

	  Outgoing Call	

Date: 5/24/2007

	

Time: 2:00 pm



	

Company Name: OSMRE Harrisburg, PA	

Contact Name:   Brent Means

Phone No.:  



	

Name:  Ellie Ku Codding and Jessica Wolford	



	

GENERAL SUBJECT:  AMDTreat® and Model Mine Concept Memorandum
Discussion



	

TOPICS DISCUSSED AND ACTION TAKEN

Thursday, May 24, 2007 at 2:00 pm, Mr. Brent Means, Office of Surface
Mining, Reclamation, and Enforcement, called to discuss AMDTreat® and
the methodology EPA proposed to calculate manganese treatment costs in
the “Model Mine Concept Memorandum.”  Ms. Ellie Codding asked Mr.
Means what the cost basis is in the current version of AMDTreat®  

Friday, May 11, 2007 at 10 am, I spoke with Mr. Mike Smith, PA DEP
Moshannon District Mining Manager.  I asked Mr. Smith if he could
estimate how often NPDES permit limits for manganese were water-quality
based, instead of being based on the Part 434 monthly-average limit of 2
mg/L.  I told him that, from what we had seen in PA NPDES permits for
coal mines, monthly-average effluent limits were 1 mg/L, which must be
water-quality based.

Mr. Smith said that permit writers first apply BAT from Part 434, to
establish the least-stringent limit.  From there, they apply
water-quality based limits or TMDLs (for those streams with TMDLs).  He
estimated that roughly half of the NPDES permit limits were Part
434-based.  For example, the Part 434 limit applies most sites with
perpetual treatment that discharge to an acid-impaired stream, because
water-quality standards may not apply to acid-impaired streams. 
Although many permit limits are water quality or TMDL based, Mr. Smith
stresses that the BAT limit for manganese is still restrictive for mines
discharging to streams that are of low quality.

We also discussed research regarding the toxicity of manganese.  Mr.
Smith agreed that most published work he has seen demonstrates no
effects of manganese on the typical chronic and acute toxicity tests,
such as for fathead minnows and ceriodaphnia.  However, anecdotally, Mr.
Ron Huey of PA DEP has observed deposits of manganese covering
streambeds.  Mr. Huey recommends a more thorough study be done to fully
study the effect on manganese on stream health, rather than focusing on
the toxicity of specific species.  For example, aquatic life that feed
on the bottom of the stream (“scum scrapers”) may be affected by
manganese coating stream beds.  Mr. Smith recommended contacting Mr. Bob
Ross, of the U.S.G.S. Research Center in Wellsboro, PA, to see if any
studies had been published (or at least considered) regarding entire
stream health and manganese.

Need to return call by         /         at/between         and        
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