Long Term Operation, Maintenance, & Replacement

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Long Term Operation, Maintenance, & Replacement
Operation, Maintenance, & Replacement
of AMD Passive Treatment Systems
•Where and
Past, Present
•Where we are now
Presented by Pam Milavec
DEP Bureau of Abandoned
Mine Reclamation
August 12, 2008
•Where we’re heading
Where have we been?
Why Operation and Maintenance?
Currently more than 259 systems in operation with a
public investment of over $77 million
 Experience has shown that passive systems have
routine operational needs, have expected and often
unexpected major maintenance requirements and will
eventually need to be replaced
 Failure to provide for OMR will result in the loss of
restored water resources and public investment
Construction: Cost to build the treatment system.
 O & M: Operation and maintenance activities including
inspections, sampling, sample analysis, flushing,
scheduled maintenance, and non-catastrophic
unscheduled maintenance.
 R: Single replacement of the system. Projected costs
may approach original construction costs.
 O, M & R: Combined operation, maintenance and
replacement costs.
O, M & R Plan Should Include
 Narrative describing O, M & R
 Maintenance agreement with all parties,
including property owners
 O, M & R Site Map
Flushing points, sample points, BMPs
 Site specific instructions
“As-built” plans
Long-term Cost Analysis
Information Sources: AMD
DEP/BAMR -actual construction and O & M costs for
existing systems plus estimated replacement costs
 NRCS - project bid cost plus estimated
O, M & R
 Stream Restoration Inc. – estimated
O, M & R for existing projects
 Hedin Environmental - estimated construction and
long-term O, M & R for Babb Creek system
Average Annual Factors for AMD
Treatment Systems *
Vertical Flow Systems.....…………..... 5%
Anoxic Limestone Drain Systems....... 4%
Compost Anaerobic wetlands............. 4%
Pyrolusite© Systems........................... 3%
Open limestone channels.................... 1%
Lime sand addition programs..….….... 33-50%
Automated lime doser......................... 13%
OMR Workgroup Average………….….4%
* Annual percentage of construction costs
Breakdown of O, M & R for
Vertical Flow Systems
Routine operations (sampling,...........
inspections, flushing)
 Water sample lab analyses ...............
 Maintenance – repairs & supplies .....
 System reconstruction......................
Total O, M & R...............................
(65% DEP provided, 35% local)
Guiding Principles for Projects in
True Sustainable Operation,
Maintenance & Replacement is
Ownership & Involvement
The goal is a system of healthy
government and local sponsors
OMR Support Strategy
 Local Sponsors provide routine operation and
 Maintenance needs assisted by local industry,
local government and/or BAMR construction staff
 DEP provides funding for more significant
maintenance and eventual system replacement
Where are we now?
Present Status:
GG projects now require OMR plans as a deliverable
GG project applications that adequately address OMR receive a
higher score, particularly when non-government sources are
 Local sponsors are expected to provide routine operations
 GG has an OMR project-type category and provides funding for
maintenance and replacement on a competitive scoring, annual
grant, basis
 WPCAMR has received a grant to fund lab analyses
 WPCAMR has received 2 Quick Response grants and has
applied for a third in the 2008 grant round
 BAMR has put together OMR task force to evaluate existing
BAMR passive treatment systems
Growing Greener O, M & R Category:
Existing Facilities
 Annual grant cycle
 Competitively Evaluated and Scored
 Evaluation and scoring criteria
O, M & R plan conceptually sound
Public-private support with local government,
residents, industry, etc.
Maintenance/replacement essential for continued
environmental benefit
WPCAMR Lab Analysis Grant
$166,000 grant provides funding for lab analysis by
local labs: Mahaffey Lab (Grampian) & G&C Lab in
 Currently covering 7 counties: Allegheny, Armstrong,
Butler, Clarion, Clearfield, Indiana and Jefferson
 Requires an OMR plan
 Has been underutilized
 Grant expired 6/30/08; an extension has been
requested but no decision has been made yet
WPCAMR Quick Response Grant
Started in 2006
A mechanism to quickly provide GG funds to local sponsors
when failure to act quickly will likely result in serious
environmental consequences or will contribute to further
damage of a project
 Current grant has a remaining balance of $189,000 and has
been extended to 6/30/09
 2007 grant adds $100,000, with an end date of 2010
 WPCAMR has applied for a new grant for the 2008 round of GG
 Applications are available on the GG web site – search under
“quick response” key words
 The application process is relatively streamlined and
Quick Response (continued)
Completed applications, with a contractor’s cost estimate
attached, are submitted to the DMO Watershed Manager
 Watershed Manager and District Mining Manager must approve
project and forward to WPCAMR
 WPCAMR sends letter to applicant stating whether funding is
approved or not
 If approved, applicant has contractor complete repairs,
Watershed Manager reviews and approves repairs, WPCAMR
then disperses funds to applicant and applies to DEP for
 Must have signed landowner access and permits, if needed
Types of Projects funded:
Damage caused by storm events – damage to ditches, berms,
intake structures and spillways (most frequent cause of funds
needed has been damage due to storm events)
 Non-storm related berm and pipe damage
 Sludge removal from compost
 Replacement of valves
 Repairs to a stream bank stabilization project after a storm event
(non-AMD project)
 11 projects funded so far; costs have ranged from $2,800 to
BAMR’s OMR Taskforce
Established to address OMR needs of BAMR-constructed
passive treatment systems
In Cambria office, 2 teams have been established that include
engineers and geologists
Have completed 2 evaluations and are currently working on 2
Most problematic sites are given top priority, but the goal is to
develop an OMR workplan for all 24 systems designed and
constructed by the Cambria Office
Harrisburg staff is focusing on BF projects designed there, while
Wilkes-Barre staff will be working on projects built by BAMR in
their District
Reports will eventually be posted on BAMR’s web site
BAMR AMD Project OMR Report Format
Project Background
Project number, name, twp., county, receiving stream
Identify what the goal of the project was and general background of the project Project info
Project design info – design methodology, design flow and quality
Project description - describe the treatment system including each individual treatment cell Status
of routine operations, past maintenance and retrofits
Status of restoration efforts in the watershed and partner viability
Property owner info and status of BAMR access rights
Attachments: (if on-line, links may be used to locate this info)
System water quality data spreadsheet in a standardized format
Stream survey report or data, if available (post-construction)
As-builts (to be completed by Inspectors/Designers/Surveyors)
Monitoring map indicating sample point ID and location
O & M/monitoring plan
Topographic map depicting treatment system location
Directions to site
Performance Evaluation and Recommendations:
Water quality data trends (may want to depict with graphs or other visuals)
Results of field review (include a discussion of any analysis or field tests completed by BAMR as part of this
Summary of current status of system
Discuss whether project goals were accomplished
Recommended Options:
Retrofit/major repair to be designed in-house and bid out
Retrofit/major repair to be designed through the passive design consultant contract and bid out
Retrofit/major repair to be undertaken by the BD crew
Continue current operation
Modify current operation, including operational or monitoring modifications
Abandon system, remove treatment system and restore area
Scope of Work for Recommended Option (if applicable)
Narrative or list of work needed
Estimated cost (identify funding source, if known)
Materials list (type and quantity), for BD projects
Attach needed drawings or schematics
Post-construction follow up Report
Once recommended work is completed, a follow-up report is to be completed and attached that includes costs and
success of recommendation
Each time a performance evaluation is initiated, the above sections should be repeated under the new date
Where are we going?
Draft Set-Aside Position Paper:
Plan to Address OMR
Successful Growing Greener Applicants to handle
routine operations
 DEP to provide mechanism to fund emergencies and
non-routine maintenance; current Quick-Response
program provides a template
 DEP to develop appropriate application to seek grants
for complete or partial system replacement
 Funds also will be provided to BAMR for
Commonwealth-constructed systems and “orphaned”
DEP has committed $2 million this year to support OMR
Set-Aside funding increases under re-authorized SMCRA will
likely be a source of funding for DEP support of OMR
The DEP will make funding decisions based on OMR costs for
current systems and what the projected costs will be for future
systems; current estimates are that the OMR need is $2
million/year, thereby requiring approx. $46 million to be deposited
into an interest-bearing fund, based on current financial
scenarios – just for the passive systems currently operating
Set Aside funds used in this manner will not be available to
construct treatment facilities, thereby reducing the overall funding
available for AMD abatement and treatment projects
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