Eric Cavazza and Brian Bradley, PA DEP, "An Analysis of PAs Accelerated Response Program- Pennsylvania's Alternative to the Federal Office of Surface Mining's (OSM) Emergency Program"
In October of 2010, the Federal Office of Surface Mining (OSM) ceased implementing the Federal Emergency Response Program to address suddenly occurring, high-priority, abandoned mine land (AML) problems in Pennsylvania. In response to the cessation of the Emergency Program by OSM, Pennsylvania chose to not accept delegation of the Emergency Program from OSM but rather to set up and Accelerated Response Program to address the AML problems traditionally dealt with by OSM.
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Eric Cavazza and Brian Bradley, PA DEP, "An Analysis of PAs Accelerated Response Program- Pennsylvania's Alternative to the Federal Office of Surface Mining's (OSM) Emergency Program"
1. An Analysis of Pennsylvania’s
Accelerated Response Program
Pennsylvania’s Alternative to the Federal Office of
Surface Mining’s (OSM) Emergency Program
Eric E. Cavazza, P.E.
and
Brian Bradley, P.G.
June 27, 2014
2. Background
October 2010:
The Federal Office of Surface Mining
(OSM) ceased implementing the Federal
Emergency Program to address
suddenly occurring, high-priority,
abandoned mine land (AML) problems
in Pennsylvania.
3. History of OSM Emergency Program in PA
Since the inception of the federally
funded AML Program in Pennsylvania
around 1980, OSM has administered
the OSM Emergency Program from the
Appalachian Regional Office in
Pittsburgh (Bituminous Region) and its
satellite Office in Wilkes-Barre
(Anthracite Region).
5. Background
In response to the cessation of the
Emergency Program by OSM,
Pennsylvania chose not to request
delegation of the Emergency Program
from OSM but rather chose to set up an
Accelerated Response Program to
address the AML problems traditionally
dealt with by OSM.
6. Accelerated Response Program
Unlike traditional OSM Emergency
Projects, accelerated response
projects require submission of a
formal written request from
Pennsylvania to OSM for an
Authorization to Proceed (ATP).
7. ARP Project Example – Green Street Subsidence, North
Belle Vernon Borough, Westmoreland County
Subsidence
Damage to
Home
8. ARP Project Example – Green Street Subsidence, North
Belle Vernon Borough, Westmoreland County
Project
Construction
10. Post Construction
• Official Start Date: December 11, 2012
• Contract Completion Date: January 9, 2013
• Project Cost: $135,262.50 (Final)
• Project Area: 0.2 Acres
• Description: Stabilized residential properties by
injecting 300 CY of pre-mixed commercially
available sand/cement grout material into the
mine voids through boreholes
11. Program Analysis - OSM Emergency Program vs. ARP
• PA’s Accelerated Response Program (ARP) has
been up and running since October of 2010
• An analysis of the first three full years of
implementation of the ARP was completed
• An analysis of the last six years of the OSM
Emergency Program was also completed
• The two programs were then compared and
contrasted
12. Analysis and Comparison of Programs
• Numbers and Types of Projects
• Geographic Location of Projects
• NEPA Compliance and ATPs
• In-House vs. Contracted Projects
• Project Costs and Manpower
• Project Construction Timeframes
• Program Implementation Summary
13. Total Number of Inquiry Investigations and Rate of
Accelerated Response Projects
Federal Fiscal Year
2011 2012 2013
Inquiries ARP Rate Inquiries ARP Rate Inquiries ARP Rate
Anthracite
District
332 49 14.8% 205 21 10.2% 216 18 8.3%
Bituminous
District
387 49 12.7% 394 29 7.4% 421 53 12.6%
Totals: 719 98 13.6% 599 50 8.3% 637 71 11.1%
Average per year: 73 Projects
14. OSM Emergency Projects in PA (FY05-FY10)
Fiscal Year Bituminous Anthracite Total
2005 99 67 166
2006 39 77 116
2007 73 66 139
2008 67 48 115
2009 81 36 117
2010 69 46 115
Totals 428 340 768
Average per year: 128 Projects
15. Number and Types of ARP Projects
Federal
Fiscal Year
BAMR
ARP
Sites
Subsidence
Mine
Drainage
Mine
Gas
Fires
Land
Slide
Mine
Opening
2011 98 81 2 1 2 6 6
2012 50 45 1 1 1 0 2
2013 71 61 2 0 2 3 3
Totals 219 187 5 2 5 9 11
Percent 85% 2% 1% 2% 4% 5%
16. Number and Types of OSM Emergencies
Federal
Fiscal
Year
OSM
Emergencies
Subsidence
Mine
Drainage
Mine
Gas
Fires
Land
Slide
Mine
Opening
2005 166 123 8 10 8 3 14
2006 116 96 2 3 3 0 12
2007 139 112 7 6 3 2 9
2008 115 96 4 2 1 4 8
2009 117 93 7 5 5 1 6
2010 115 86 5 4 2 1 17
Totals 768 606 33 30 22 11 66
Percent 79% 4% 4% 3% 1% 9%
17. Comparison of AML Problem Types -
OSM Emergency Program
vs. PA ARP Program
AML Problem Type
Program Subsidence
Mine
Drainage
Mine
Gas
Fires
Land
Slide
Mine
Opening
OSM Emergency 79% 4% 4% 3% 1% 9%
PA-DEP ARP 85% 2% 1% 2% 4% 5%
24. Project Summary
Response Timeline:
Notification Received: September 12, 2011
ATP Requested: September 14, 2011
ATP Issued: September 14, 2011
Construction Started: September 29, 2011
Construction Completed: October 20, 2011
Construction Duration: 21 Calendar Days
Reclamation Method: Contract
Project Cost: $85,812
29. Project Summary
Response Timeline:
Notification Received: May 22, 2012
ATP Requested: May 23, 2012
ATP Issued: May 24, 2012
Construction Started: May 24, 2012
Construction Completed: May 30, 2012
Construction Duration: 6 Calendar Days
Reclamation Method: In-House Construction Crew
with rental equipment
Project Cost: $25,961.52
30. Significant Differences between PA’s ARP and
the OSM Emergency Program
• ARP Projects require an Authorization to
proceed (ATP) and full NEPA Compliance prior
to construction
• PA has two in-house construction crews
capable of responding and completing
necessary reclamation for small ARP projects
31. Time in Days from Notification to Request of ATP
PA-BAMR ARP Projects (FY2011 - FY2013)
Time
No. of
Projects
Percent
Cumulative
Percent
Same Day 15 6.8% 6.8%
1 - 3 Days 51 23.3% 30.1%
4 - 7 Days 49 22.4% 52.5%
8 -14 Days 42 19.2% 71.7%
15 - 21 Days 18 8.2% 79.9%
22 - 30 Days 10 4.6% 84.5%
31 - 60 Days 10 4.6% 89.0%
61 - 200 Days 5 2.3% 91.3%
No Data/Not Required 19 8.7% 100.0%
Totals 219
Typical ATP Request Times
Average Request Time 12.0 Days
Median Request Time 7 Days
32. Time in Days for OSM to Review and Issue ATP
PA-BAMR ARP Projects (FY2011 - FY2013)
Time
No. of
Projects
Percent
Cumulative
Percent
Same Day 76 34.7% 34.7%
1 - 3 Days 93 42.5% 77.2%
4 - 7 Days 24 11.0% 88.1%
8 -14 Days 3 1.4% 89.5%
15 - 21 Days 1 0.5% 90.0%
22 - 30 Days 0 0.0% 90.0%
31 - 60 Days 1 0.5% 90.4%
61 - 200 Days 1 0.5% 90.9%
No Data/Not Required 20 9.1% 100.0%
Totals 219
Typical ATP Times
Average Review Time 2.7 Days
Median Review Time 1 Days
33. Reclamation Method used to Complete
ARP Projects
Reclamation
Method
Anthracite
District
Bituminous
District
Statewide Percent
In-house Crews 52 105 157 71.7%
Contracted 30 25 55 25.1%
By Others 6 1 7 3.2%
Totals: 88 131 219
34. Anthracite In-House Project Example – Project AD860X,
Hazle Township, Luzerne County
Mine Subsidence
Cavehole in
Parking Lot
March 16, 2011
36. Anthracite In-House Project Example – Project AD860X,
Hazle Township, Luzerne County
Reclaimed
Mine Subsidence
Cavehole in
Parking Lot
March 25, 2011
37. Project Details
• Notification and Investigation: March 16, 2011
• Opening under pavement measuring 11 feet in
diameter and 13 feet in depth
• In-House Construction Crew (AD Crew)
completed the backfilling and remediation on
March 25, 2011 (Completed in 9 calendar days)
• The void was backfilled with 44 tons of R-5 Rock
and 19 cubic yards of Grout
• Project cost: $3,186.37
38. Costs to Complete ARP Projects by
Region (FY2011 - FY2013)
Anthracite
District
Bituminous
District
Statewide
Cost
Percent
In-house
Crews
$107,047 $247,278 $354,325 7.3%
Contracted $1,506,160 $3,005,645 $4,511,805 92.7%
Totals: $1,613,207 $3,252,923 $4,866,130
Average Annual Construction Cost: $1,622,043
39. Total Construction Cost of OSM Emergency Projects in PA
Fiscal
Year
Bituminous Anthracite Total
2005 $ 2,068,914 $ 821,235 $ 2,890,149
2006* $ 786,795 $ 12,561,256 $ 13,348,051
2007 $ 1,254,882 $ 1,125,471 $ 2,380,353
2008 $ 1,795,353 $ 1,234,078 $ 3,029,431
2009 $ 1,427,739 $ 500,881 $ 1,928,620
2010 $ 1,286,236 $ 381,033 $ 1,667,269
Totals $ 8,619,919 $ 16,623,954 $ 25,243,873
*Includes $11,415,001 for the Dolph Mine Fire Control Project
Average Annual Construction Cost: $2,304,821
40. ARP Construction Cost Range
and Typical Project Costs
ARP Project Costs
(FY2011 – FY2013)
Cost Range No. of Projects
> $100,000 11
$50,000 - $100,000 15
$25,000 - $50,000 10
$10,000 - $25,000 15
$5,000 - $10,000 11
Contracts < $5,000 150
Total 212
Typical Project Values
Average Project Cost* $23,062
Median Project Cost* $1,679
*- Excluding projects completed by others
41. Analysis of Emergency Project Costs
Contract Range No. of Projects
Contracts > $100,000* 33
$50,000 - $100,000 26
$25,000 - $50,000 53
$10,000 - $25,000 94
$5,000 - $10,000 53
Contracts < $5,000 509
Total 768
* - Includes Dolph Colliery Mine Fire Control Project
Typical Project Values
Average Project Cost** $18,840
Median Project Cost** $2,000
**- Excluding the Dolph Colliery Mine Fire Control Project and projects
completed by others or with no cost information
42. Manpower Resources Required
Implementing the Program (FTEs)
Fiscal
Year
Total ARP
Hours
Full Time
Equivalents
(FTE)
Salary and
Fringe
Benefit
Costs
2011 10,292 5.72 $ 445,224
2012 10,176 5.65 $ 397,740
2013 7,884 4.38 $ 340,793
Totals: 28,352 5.25 $ 1,183,757
43. Staff Effort shown as Bi-weekly Full Time Equivalents
(Federal Fiscal Years FY2011 – FY2013)
0.0
2.0
4.0
6.0
8.0
10.0
12.0
14.0
16.0
18.0
FullTimeEquivalents
ARP Bi-weekly Work Effort as FTE
Biweekly FTE
Average FTE
44. Total, 3-year, manpower and construction costs to
implement the Program
Cost Percent
In-house Construction Cost $ 354,325 5.9%
Contract Cost $ 4,511,805 74.6%
Salary and Benefit cost $ 1,183,757 19.6%
Total Cost: $ 6,049,887
Average cost based on 219 ARP Projects: $ 27,625.05
45. Bituminous In-House Project Example – Project
BD3168ARBP, South Park Township, Allegheny County
Mine Subsidence
Cavehole in
Residential Yard
July 16, 2013
46. Bituminous In-House Project Example – Project
BD3168ARBP, South Park Township, Allegheny County
Project
Construction
47. Bituminous In-House Project Example – Project
BD3168ARBP, South Park Township, Allegheny County
Reclaimed
Mine Subsidence
Cavehole in
Residential Yard
September 4, 2013
48. Project Details
• Notification and Investigation: July 16, 2013
• Bell-shape opening in yard area measuring 15
feet in diameter (max) and 15 feet deep
• In-House Construction Crew (BD Crew)
completed the backfilling and remediation on
August 9, 2013 (Completed in 24 calendar days)
• The void was backfilled with 49 tons of stone and
the yard area was restored and planted
• Project cost: $3,111.99
49. Time in Days from Notification to Initiation of Construction
PA-BAMR ARP Projects (FY2011 - FY2013)
Time
No. of
Projects
Percent
Cumulative
Percent
0 - 3 Days 21 9.6% 9.6%
4 - 7 Days 19 8.7% 18.3%
8 -14 Days 43 19.6% 37.9%
15 - 21 Days 33 15.1% 53.0%
22 - 30 Days 31 14.2% 67.1%
31 - 60 Days 34 15.5% 82.6%
61 - 90 Days 13 5.9% 88.6%
91 - 120 Days 6 2.7% 91.3%
121 - 180 Days 7 3.2% 94.5%
> 181 Days* 5 2.3% 96.8%
No Data (by others) 7 3.2% 100.0%
Totals: 219 100.0%
Typical Response Times
Average Response Time* 39.4 Days
Median Response Time 21.5 Days
* - Includes 2 Projects > 365 Days
50. Days from Notification to Initiation of Construction
OSM Emergency Projects (FY2005 - FY2010)
Time
No. of
Projects
Percent
Cumulative
Percent
0 - 3 Days 52 6.8% 6.8%
4 - 7 Days 97 12.6% 19.4%
8 -14 Days 154 20.1% 39.5%
15 - 21 Days 103 13.4% 52.9%
22 - 30 Days 83 10.8% 63.7%
31 - 60 Days 119 15.5% 79.2%
61 - 90 Days 57 7.4% 86.6%
91 - 120 Days 35 4.6% 91.1%
121 - 180 Days 27 3.5% 94.7%
> 181 Days* 22 2.9% 97.5%
Addressed by Others 19 2.5% 100.0%
Totals 768 100%
Typical Response Times
Average Response Time* 39 Days
Median Response Time 20 Days
* - Includes 3 Projects > 365 Days
51. Time in Days from Notification to Completion of Construction
PA-BAMR ARP Projects (FY2011 - FY2013)
Time
No. of
Projects
Percent
Cumulative
Percent
0 - 7 Days 17 7.8% 7.8%
8 -14 Days 31 14.2% 21.9%
15 - 21 Days 28 12.8% 34.7%
22 - 30 Days 28 12.8% 47.5%
31 - 60 Days 55 25.1% 72.6%
61 - 90 Days 13 5.9% 78.5%
91 - 120 Days 12 5.5% 84.0%
121 - 180 Days 13 5.9% 90.0%
181 - 365 Days 11 5.0% 95.0%
> 365 Days 4 1.8% 96.8%
By Others 7 3.2% 100.0%
Totals 219 100.0%
Typical Completion Times
Average Completion Time 61.3 Days
Median Completion Time 31 Days
52. Days from Notification to Completion of Project Construction
OSM Emergency Projects (FY2005 - FY2010)
Time
No. of
Projects
Percent
Cumulative
Percent
0 - 7 Days 0 0.0% 0.0%
8 -14 Days 5 0.7% 0.7%
15 - 21 Days 21 2.7% 3.4%
22 - 30 Days 26 3.4% 6.8%
31 - 60 Days 154 20.1% 26.8%
61 - 90 Days 107 13.9% 40.8%
91 - 120 Days 97 12.6% 53.4%
121 - 180 Days 77 10.0% 63.4%
181 - 365 Days 111 14.5% 77.9%
> 365 Days* 56 7.3% 85.2%
No Data or By Others 114 14.8% 100.0%
Totals 768 100%
Typical Completion Times
Average Completion Time* 148 Days
Median Completion Time 94 Days
* - Includes 10 Projects > 730 Days (2 years)
53. Selected Comparison of OSM Emergency
Program to PA ARP Program
Program Metric
OSM
Emergency
PA-BAMR
ARP
Average Annual Number of Projects 128 73
Average Project Construction Cost $18,840 $23,062
Median Project Construction Cost $2,000 $1,679
Percent of Projects with Cost < $5,000 66.3% 70.8%
Average Annual Construction Expenditures
(Excludes OSM’s Dolph Project at $11.4M)
$2,304,821 $1,622,043
Average Total Days to Initiate Construction 39 39.4
Median Total Days to Initiate Construction 20 21.5
Percent of projects Initiated in 60 days or less 79.2% 82.6%
Average Total Days to Complete Construction 148 61.3
Median Total Days to Complete Construction 94 31
Percent of projects Completed in 60 days or less 26.8% 72.6%
54. ARP Program Implementation Summary
• Set up ARP Program with no additional staff
• Absorbed total costs (staff and project
costs) with regular Title IV Grant funds
• Utilized existing in-house construction
crews to expedite response
• Developed accelerated contracting
procedures and construction management
protocols for ARPs
55. Simpson Refuse Pile Fire (Jan. 2014)
Fell Township, Lackawanna County
• 2014 turning out to be a non-typical year
• Over $2.8 million in ARP contracts
(October 1, 2013 – June 20, 2014)
56. Simpson Refuse Pile Fire – Construction
Lackawanna River
Water Supply Pump
Borehole for
Monitoring
Temperatures
Fire
Suppression
Surfactant
Water Supply Hose Line
57. Simpson Refuse Pile Fire Summary
Response Timeline:
Notification Received: December 15, 2013
ATP Requested: December 24, 2013
ATP Issued: January 3, 2014
Construction Started: January 20, 2014
Construction Completed: May 28, 2014
Construction Duration: 129 Calendar Days
Reclamation Method: Contract
Project Cost: $2,213,477.80
59. Acknowledgements
The presenters would like to acknowledge
and thank Rick Balogh and his staff of the
Office of Surface Mining, Appalachian
Regional Office, for their cooperation and
assistance in providing information
regarding the OSM Emergency Projects
completed in Pennsylvania for federal fiscal
years FY2005 – FY2010.