DEP Citizens Advisory Council Meets March 17 On New Pipeline Construction Guidance, Act 54 Report On Damage Caused By Deep Coal Mining, Chapt. 105 Alternatives Analysis

The DEP Citizens Advisory Council is scheduled to meet on March 17 to discuss DEP’s draft policy on pipeline construction and the latest Act 54 report detailing damage caused by underground coal mining.

Also on the Council agenda is a discussion of Chapter 105 Water Obstruction and Encroachments Alternative Analysis Guidance Document.

Pipeline Construction Guidance

DEP developed the draft Trenchless Technology Guidance Document to outline the policies, procedures and best practices for the prevention of adverse environmental impacts from constructing pipelines using horizontal drilling techniques.

The guidance is designed to help avoid the significant environmental problems that have been happening during the ongoing construction of the Mariner East Pipelines.

To help develop the guidance, DEP formed a Work Group that has issued a draft report and recommendations as background on the guidance.

Among other issues, the guidance covers--

-- Site-specific geological, topographical, and hydrological analysis to be considered;

-- Type of analysis and documentation of adjacent features in the vicinity of the project footprint;

-- Potential impact of the planned activity on or from adjacent features;

-- Enhanced Best Practices for:

-- Preventing and responding to Inadvertent Returns (IRs);

-- Preventing and responding to hydrological impacts from IRs;

-- Groundwater quality and quantity protection; and

-- Procedures to identify water supplies in the vicinity of a proposed HDD beyond the use of the Pennsylvania Groundwater Information System

-- Recommendations for permittee to conduct water supply testing (quality and quantity) for landowners within the vicinity of an HDD.

DEP has discussed the guidance with the Agricultural Advisory Board,  Environmental Justice Advisory Board,  Small Water Technical Advisory Committee and the  Water Resources Advisory Committee.

Andrew Foley and Rebecca Dunlap from DEP’s Regional Permit Coordination Office will make a presentation to the Council.

Click Here for a copy of the Stakeholder Report and draft Guidance.  Click Here for a copy of the presentation.

Act 54 Mining Damage Report

On December 19, the Department of Environmental Protection released the 2013-2018 Act 54 Assessment Report, the fifth in a series of reports required by Act 54 of 1994 documenting the impacts of underground coal mining on surface structures, water supplies, streams, land damage, groundwater and wetlands.

The report, done by the University of Pittsburgh, analyzed the impacts of 49 underground bituminous coal mine operations which undermined 28,854 acres in Greene and Washington counties during the reporting period of 2013-2018.

Among the damage reported was--

-- 40% Of Streams Damaged: This report, like the last one, found 40 percent of streams undermined by deep coal mining experienced multiple impacts such as loss of flow or pooling and their Total Biological Score decline significantly.

-- 192 Water Supplies Impacted: The report found 379 water supplies were affected underground of which 192 were determined to be the mining company’s fault and 73 were catego

-- Structures Damaged: Of the 3,612 structures undermined during this period, there were a total of 391 effects from active mines and an additional 64 reported impacts from mines there were in active during 2013-2018 totalling 455 structures. The average time for all structural final resolutions was 162 days.  This is down slightly from previous reports.

-- Wetlands Lost: An estimated 90.7 acres of wetland habitat were undermined and of the five longwall mines reporting pre- and post-mining wetland acreage, only one mine reported a loss of wetlands acreage, the others reported a slight gain due to stream and other changes to the landscape.

The report contained a number of recommendations, including--

-- Damage Is Occurring At Distances Beyond What Is Expected: “...  during this assessment, unexpected impacts were observed. Far-field subsidence impacts occurred at distances well beyond those predicted by models accepted by the ground control scientific and engineering community.

-- Comprehensive Evaluation Of Subsidence Impacts Needed: “Attempts to simplify management of subsidence need to be coupled with comprehensive examination of the larger implications.

-- Outdated Database Systems: The Bituminous Underground Mining Information database system used by DEP is over 25 years old and gathering and QA/QC checking remains the largest portion of the total University effort on this project.

Click Here for a more detailed summary of the report.
Bill Allen, Director of DEP’s Bureau of Mining Programs will be giving the presentation.

Visit DEP’s Act 54 Mining Reports webpage for a copy of this report and previous Act 54 reports.

Chapt. 105 Alternatives Analysis

The draft Chapter 105 Alternatives Analysis Technical Guidance outlines the process applicants undertake to document their efforts to avoid or minimize the environmental impacts of their proposed water obstruction or encroachment into wetlands or other regulated areas to the greatest extent practicable.

The analysis takes into consideration cost, existing technology and logistics for both on-site or off-site alternatives.

In addition to provisions applying to the typical project covered by Chapter 105, the draft Guidance contains project specific considerations for linear projects like pipelines, utility lines, energy and power transmission lines; transportation projects; restoration and pollution abatement projects.

DEP has discussed the guidance with the Agricultural Advisory Board,  Environmental Justice Advisory Board,  Oil and Gas Technical Advisory Board and the Water Resources Advisory Committee.

Andrew Foley and Rebecca Dunlap from DEP’s Regional Permit Coordination Office will also be making this presentation to Council.

Click Here for a copy of DEP’s presentation.  Click Here for a copy of the draft Guidance.

The meeting will be held in Room 105 of the Rachel Carson Building in Harrisburg starting at 10:00 a.m.  A Conference Call-In number is available:: (267) 332-8737; Conference ID #: 941265504.

For more information and available handouts, visit the DEP Citizens Advisory Council webpage.  Questions should be directed to Keith Salador, Executive Director, 717-787-8171 or ksalador@pa.gov.

(Photos From Act 54 Report: top left/middle - impact of heave on Whitethorn Run over Bailey Mine and stream after heave cut was made; top right- damage to home by Enlow Fork Mine; bottom left- mitigation for gas line over Enlow Fork Mine; bottom middle- mitigation trench dug around a home over Contura Mine; bottom right- timber bracing used to stabilize structure during mining.)

Related Article:

Act 54 Report Again Finds 40% Of Streams Suffered Loss Of Flow, Pooling, Reduction In Biological Activity Due To Impacts From Underground Coal Mining

[Posted: March 5, 2020]  PA Environment Digest