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State Innovation Grants
EPA 2005-2006 State Innovation Grants Competition Pre-ProposalsEPA State Innovation Grant Program Idea
Submitted by the West Virginia Department of Environmental Protection
Division of Land Restoration
EPA State Innovation Grant Program-Draft Proposal
EPA Topic Area-National Environmental Performance Track Program and State Performance-Based Environmental Leadership Programs
Watershed Based Approach to Acid Mine Drainage Treatment
Effective treatment of some streams impaired by acid mine drainage in West Virginia can be accomplished on a watershed basis if not for the current constraints of the Clean Water Act.
Traditional command and control environmental strategies have improved the quality of our environment dramatically from where it was thirty years ago, but much more needs to be done to meet established standards, foster an individual and corporate mindset that encourages true environmental stewardship, and complement the future of performance-based environmental leadership programs. Incentive and recognition programs like EPA’s National Environmental Performance Track and West Virginia’s Environmental Excellence program reward efforts and strategies that go well beyond meeting minimum standards while maintaining flexibility and recognizing the link between sound environmental practices and community and economic health. West Virginia DEP proposes an innovative way to improve water quality on a watershed basis by using the federal and state programs to overcome the constraints of the Clean Water Act.
A study conducted by the West Virginia Water Research Institute and funded by the West Virginia Department of Environmental Protection demonstrated that a single stream headwater treatment approach as compared to the traditional point source treatment approach to acid mine drainage would provide superior environmental results across both the mining reclamation and water resources programs. Funding currently targeted to treating a limited universe of acid mine discharges from bond forfeited mine sites could also treat a much larger universe of abandoned mine discharges if the treatment was redirected to a watershed based approach.
West Virginia currently has around 500 streams covering 2500 miles that are impaired for acid mine drainage.
The majority of cost associated with the treatment of acid mine drainage (AMD) is controlled by the following factors:
| Factor 1. | Site access | S |
| Factor 2. | Construction | C |
| Factor 3. | Alkalinity addition | A |
| Factor 4. | Oxidation requirement | O |
| Factor 5. | Sludge disposal | D |
AMD treatment, like most enterprises, benefits from economies of scale. The most efficient scenario involves a single, large volume discharge with a single access point and large scale, one time construction. One time mobilization of construction equipment, construction of a single access road, relative few access agreements is obviously less expensive than treating the same amount of acid load at 10 or 100 locations. Viewed simply, in AMD treatment the metric that determines the program’s effectiveness is the mass of alkalinity that is delivered to impaired streams (factor 3, above). As the number of treatment sites increases, the proportion of program cost devoted to alkalinity addition decreases as access, construction and sludge disposal costs dominate. It is generally assumed that the cost of AMD treatment equals the cost of alkalinity x 2 to account for the other four factors. Treatment for manganese generally doubles the total cost. So the cost of AMD treatment at a given site can be described by equation 1:
equation 1: AMD Cost = S+C+A+O+D
There are many ways to estimate environmental benefits but for the sake of argument recovered stream miles will be used. Thus, the environmental efficiency of a treatment program would be described by equation 2:
equation 2: Environmental efficiency = AMD Cost/ Recovered stream miles
Viewed in a Statewide context, the Special Reclamation Fund is the largest of many programs that treat AMD. Others include: the AML program, 10% set aside program, Clean Streams program, Watershed Cooperative Agreements, CWA sec. 319 program. All of these programs play a role in meeting watershed remediation objectives as outlined under CWA sec 303. TMDL and TMDL implementation programs. All of these programs will ultimately be evaluated according to their environmental efficiency.
The Evaluation of Acid Mine Drainage Treatment Strategies Under the Special Reclamation Fund provides a compelling argument that superior environmental performance may be gained by employing this alternative treatment strategy under certain watershed conditions. The WVDEP believes that the recently enacted Environmental Excellence Program (HB 4027) is an appropriate mechanism to implement the alternative treatment strategy at the state level. The WVDEP further believes the Environmental Excellence Program provides an appropriate platform to enter discussions with USEPA to address relevant federal Clean Water Act requirements through reciprocal USEPA programs promoting superior environmental performance.
The WVDEP proposes to utilize the EPA State Innovation Grant in defining the process and procedures designed to secure superior environmental performance in watersheds that qualify for the alternative acid mine drainage treatment strategy.
Budget:
Two DEP Project Managers $***
One year salary plus benefits and indirect
Budget: $192,000
Point of Contact: Ken Ellison, Director
Division of Land Restoration
WVDEP
601 57 th Street
Charleston, West Virginia 25304
Tel: (304) 926-0440
Fax: (304) 926-0447
Email: kellison@wvdep