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Set Aside Treatability Guidelines. Brent Means U.S. Office of Surface Mining. Introduction. The SA program is ~ 14 years old. The AML reauthorization provides an opportunity and reason to perform a review of the SA program.

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slide1

Set Aside Treatability Guidelines

Brent Means

U.S. Office of Surface Mining

slide2

Introduction

  • The SA program is ~ 14 years old
  • The AML reauthorization provides an opportunity and reason to perform a review of the SA program
  • The workgroup was formed to produce guidelines that would form the basis for future project selection
  • The guidelines contain both project selection and treatability criteria
slide3

Project Selection and Treatability Document: Guiding Principals

Achieving and maintaining restoration is most important

SA program should be expanded to consider any type of treatment (not just passive)

Restoration should be done in a “comprehensive” manner

slide4

Treatability Criteria

  • The goal of the criteria is to ensure the proposed treatment or abatement strategy is an appropriate match for the water quality and site conditions
  • The treatability scoring is based on three evaluations:
  • A “Proven” evaluation: focused on evaluating whether the proposed scenario is proven to provide treatment
  • A “Reliability” evaluation: an operational evaluation
  • A “Predictable” evaluation: a maintenance evaluation
  • The proposed treatment project is evaluated against the criteria for each of the three assessments, resulting in an overall score for the Treatability section of the document
slide5

Proven Evaluation

A “proven” technology is a treatment or abatement technique that:

  • is successfully used at numerous locations under treatment scenarios similar to the proposed project;
  • is sized or manufactured using a science-base approach that can be evaluated
  • has a data-supported performance record
slide6

Reliable Evaluation

A “reliable” treatment or abatement technology is one that:

  • Can achieve the treatment/abatement goals > 90% of the design life;
  • Can be operated and maintained to consistently achieve treatment/abatement goals;
  • Can be manipulated to achieve treatment/abatement goals under varying flow, chemistry, and operational conditions;
slide7

Predictable Evaluation

A “predictable” treatment or abatement technology is one that:

  • contains troubleshooting capacity;
  • can be maintained or rehabilitated if the treatment/abatement goals are not being achieved;
  • has maintenance flexibility built into the treatment scheme;
slide8

Set Aside projects are arranged into 6 Categories

  • Active Treatment
  • Passive Treatment of Net Alkaline discharges
  • Passive Treatment of Net Acidic discharges using ALD
  • All other types of Passive Treatment for Net Acidic water
  • Innovative Technology
  • Abatement projects
  • All SA projects fit into one of these categories and evaluated against the “Proven”, “Reliable,” and ‘Predictable” scoring criteria
slide9

Example using Active Treatment

Proven Evaluation:

  • is successfully used at numerous locations under treatment scenarios similar to the proposed project;
  • is sized or manufactured using a science-base approach that can be evaluated
  • has a data-supported performance record

** Can automatically receive a high proven score if it is commonly used to achieve water quality based standards in similar situations

  • Other factors that affect the “Proven” evaluation
slide10

Example using Active Treatment

  • Other factors that affect “Reliability” evaluation:
  • Ability to achieve treatment goals under the range in hydrologic and geochemical conditions characterized at the site
  • Ability to continue treatment during desludging
  • Ease of operation

Reliable Evaluation (deals with operational issues) :

  • Evaluate the likelihood that the recommended system can achieve the treatment/abatement goals > 90% of the design life;
  • Evaluate whether the proposed system can be operated and maintained to consistently achieve treatment/abatement goals;
  • Evaluate whether the proposed system can be manipulated to achieve treatment/abatement goals under varying flow, chemistry, and operational conditions
  • Evaluate whether the proposed system be operated to achieve varying degrees of treatment
slide11

Example using Active Treatment

Predictability Evaluation (deals with maintenance issues) :

  • Evaluate the whether the proposed system contains the capacity to easily troubleshoot operational problems;
  • Evaluate whether the proposed system can be easily maintained or rehabilitated if the treatment/abatement goals are not being achieved;
  • Evaluate whether the proposed system contains maintenance flexibility built into the treatment scheme;
  • Other factors that affect the “Predictability” evaluation
  • Time frame between chemical replenishment
  • Time frame between desludging events
  • Sludge handling
  • Longevity of sludge storage volume
slide12

Treatability Evaluation

  • Active Treatment - covered
  • Passive Treatment of Net Alkaline Discharges
  • Promoted by automatically receiving a high “proven” score
  • Scoring is affected by sludge handling, sludge storage volume, addresses the effects of temp., etc.
  • Passive Treatment of Net Acidic Discharges using ALDs
  • Promoted by automatically receiving a high “proven” score
  • Ease of troubleshooting system, sludge handling, rehabilitation plan
  • All other types of passive treatment for Net Acidic discharges using passive Treatment
slide13

Treatability Evaluation

  • All other types of passive treatment for Net Acidic discharges using passive Treatment

Proven Evaluation:

  • Discharge characteristics are compared against risk matrix to obtain a score
  • Risk Matrix was developed on the premise that passive treatment (e.g. VFP) best performs (longevity, maintenance) on low-loading discharges
  • The intent of the risk matrix is to provide a structured approach for project selection that would be continuously refined as projects are completed and performance is field-validated
slide15

All other Passive Treatment on Net Acidic water

  • Other factors that affect “Reliability” evaluation:
  • Ability to control flow into the system
  • Ease of treatment operation
  • Ability to continue treatment during desludging or rehabilitation events

Reliability Evaluation:

  • Evaluate the likelihood that the recommended system can achieve the treatment/abatement goals > 90% of the design life;
  • Evaluate whether the proposed system can be operated and maintained to consistently achieve treatment/abatement goals;
  • Evaluate whether the proposed system can be manipulated to achieve treatment/abatement goals under varying flow, chemistry, and operational conditions
  • Evaluate whether the proposed system be operated to achieve varying degrees of treatment
slide16

All other Passive Treatment on Net Acidic Water

  • Other factors that affect the “Predictability” evaluation
  • Ability to monitor the progression of plugging
  • Ease of troubleshooting treatment system
  • Time frame between rehabilitation events
  • A plan to dispose of compost or limestone

Predictability Evaluation (deals with maintenance issues) :

  • Evaluate the whether the proposed system contains the capacity to easily troubleshoot operational problems;
  • Evaluate whether the proposed system can be easily maintained or rehabilitated if the treatment/abatement goals are not being achieved;
  • Evaluate whether the proposed system contains maintenance flexibility built into the treatment scheme;
slide17

Treatability Evaluation

  • Innovative Technology
  • AML money is not permitted for “research” activities
  • Innovative Technologies would be subject to a “proven, reliability (operation), and predictability (Maintenance)” evaluations
  • Abatement Projects
  • Abatement Projects would be subject to a “proven, reliability (operation), and predictability (Maintenance)” evaluations
  • The background data should be sufficient enough to show the cause/effect relationship between the mining feature and the affected water resource
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