CMM Environmental Reclamation Standards 4 — Questions and Answers
Question 1: What is the purpose of a 'hydrologic reclamation plan' required under SMCRA permit applications?
- To project future water demand for mine dewatering pumps
- To demonstrate how mining and reclamation will minimize disturbance to the hydrologic balance (Correct answer)
- To map all surface water features within 500 feet of the permit area
- To calculate the volume of stormwater retention ponds needed during operations
Correct answer: To demonstrate how mining and reclamation will minimize disturbance to the hydrologic balance
A hydrologic reclamation plan demonstrates how the operator will minimize adverse impacts to the hydrologic balance of the watershed during and after mining.
Question 2: Under SMCRA, what restriction applies to surface coal mining operations in or near alluvial valley floors in the arid and semi-arid West?
- Mining is completely prohibited within alluvial valley floors
- Operations must not interrupt, discontinue, or preclude farming on alluvial valley floors (Correct answer)
- A 300-foot buffer zone must be maintained from all alluvial valley floors
- Groundwater extraction from alluvial aquifers requires special EPA authorization
Correct answer: Operations must not interrupt, discontinue, or preclude farming on alluvial valley floors
SMCRA prohibits surface coal mining operations from interrupting, discontinuing, or precluding farming on alluvial valley floors used for farming in the arid and semi-arid West.
Question 3: What is a 'sedimentation pond' (or settling pond) designed to accomplish at a surface mine?
- Store process water used for ore washing and beneficiation
- Capture and settle suspended solids from stormwater runoff before discharge (Correct answer)
- Prevent groundwater from infiltrating active pit areas
- Treat acid mine drainage through chemical neutralization
Correct answer: Capture and settle suspended solids from stormwater runoff before discharge
Sedimentation ponds capture runoff from disturbed areas and allow suspended solids to settle before water is discharged, reducing total suspended solids in mine effluent.
Question 4: What does the 'valid existing rights' (VER) exception under SMCRA allow?
- Continued mining in areas otherwise prohibited if the operator had valid mining rights before the prohibition was enacted (Correct answer)
- Transfer of reclamation obligations to the state when federal oversight lapses
- Exemption from bond requirements for operators with a 10-year compliance history
- Reduction of revegetation success standards on previously mined land
Correct answer: Continued mining in areas otherwise prohibited if the operator had valid mining rights before the prohibition was enacted
VER allows operators who held valid property rights or mining rights before certain prohibitions were enacted to continue operations in otherwise protected areas.
Question 5: A reclamation bond calculated using 'cost estimation' methodology must account for what primary cost element?
- Market value of minerals remaining in the unmined permit area
- Third-party contractor cost to complete reclamation if the operator defaults (Correct answer)
- Administrative costs of state regulatory program oversight
- Environmental monitoring costs for five years post-reclamation
Correct answer: Third-party contractor cost to complete reclamation if the operator defaults
Bond amounts must reflect the cost a regulatory authority would incur to hire a third-party contractor to complete all reclamation if the operator fails to perform.
Question 6: What is the significance of 'Phase III' bond release under SMCRA's three-phase bond release process?
- Release of 60% of the bond after grading is complete
- Release of 25% of the bond after drainage structures are stabilized
- Release of the remaining bond after the full revegetation liability period ends (Correct answer)
- Release of the bond when the permit is administratively closed
Correct answer: Release of the remaining bond after the full revegetation liability period ends
Phase III bond release (the final remaining portion) occurs after the operator successfully completes the full revegetation liability period, demonstrating long-term vegetation success.
Question 7: Which concept describes the requirement that reclaimed land must support the uses it was capable of supporting before mining, or a higher and better use?
- Approximate original contour standard
- Post-mining land use suitability standard
- Pre-mining land capability standard (Correct answer)
- Equivalent use doctrine
Correct answer: Pre-mining land capability standard
SMCRA's pre-mining land capability standard requires reclaimed land to support the uses it was capable of before mining, with allowances for approved higher and better uses.
CMM Environmental Reclamation Standards 4
What is the purpose of a 'hydrologic reclamation plan' required under SMCRA permit applications?