The current procedures for remining in Ohio actually discourage rather than encourage the practice. Therefore, current practices delay reclamation which would physically improve the environment. The current regulatory standard for background sampling for coal remining permits is 12 months of samples, sampled once or twice monthly. Pennsylvania is the only state in the Midwest whose remining program successfully encourages reclamation of pre 1977 mined areas. Pennsylvania's program is successful because it is standardized and designed to give the operator a quick response and a large degree of control over the process.
Flow rate is the primary factor that determines the variability of pollutant load.
The pollutant load estimate must compensate for this cycle. The following recommendations were drawn from the survey of the neighboring states, literature research, and interviews with regulatory and coal industry personel. Changing the sampling interval from 12 months to 6 months will make remining and regular coal permits comparable in requirements, and will not be a disincentive to obtaining modified effluent permits. This change can be made and still adequately protect the environment. In fact, as it will encourage coal remining in Ohio, it potentially will have the effect of greatly improving the environment because of the associated reclamation of abandoned coal mines.