Conclusions and Recommendations - Coal Waste Impoundments: Risks, Responses, and Alternatives - page 156

category and should determine which mitigation measures should be
applied to reduce this risk to an acceptable level.
The committee also concludes that the design process for impoundments
would be improved by a more formal risk analysis. Proposed new
impoundments should also be assigned to risk categories, based on a
combination of hazards and consequences, as was suggested for existing
impoundments. To maximize the potential for risk reduction, the committee
recommends that all impoundment designs be accompanied by a risk
analysis utilizing qualitative methods. Examples of such methods include
Potential Problem Analysis and Failure Modes and Effects Analysis.
The committee believes there is a limit to risk tolerance, for both existing
and new impoundments. When risk is high, and when mitigation either through
more reliable characterization or barrier construction is impossible, of limited
precedent, or so expensive that it is infeasible, then a substantial change in
operation of the impoundment is warranted. This may range from minimizing
slurry fluidity to cessation of operation. Impoundments that fail risk-assessment
criteria and where risk cannot be mitigated should be phased out or alternatives
considered.
The committee heard repeatedly that the current review process for
impoundment approval could take 2 years or more to complete. The committee
believes that an efficient and coordinated regulatory review process would have
substantial public benefit. A well-coordinated technical review process would
protect health and safety of both miners and the public, and would foster
protection of the environment. Therefore, the committee recommends that
the review process for both new permits and existing permits be
overhauled to include the following elements:
• A formal joint review that would coordinate the currently fragmented
and inefficient collection of reviews into a single process.
• Sufficient staff for engineering and other reviews in the agencies that
participate in the joint process so that the time required to complete
the review can be reduced significantly.
The committee found that only very limited information was available
concerning the quantities of trace elements in the slurry and the associated
water. The committee heard repeatedly that citizens are concerned about ground
and surface water quality and the impacts of impoundments on them. While a
detailed review of the environmental impacts of coal waste impoundments is
beyond the scope of this study, the committee identified this area as one
needing further study. In addition, the character of the