Each operating location takes a precise, tailored approach to water quality management — one based on a comprehensive evaluation of water needs, relevant habitats, and potential impacts.
Over the years, Arch has continually intensified its focus on oversight and reporting accuracy through increased employee training, and the broad implementation of real-time alert systems. As part of this effort, the Arch team employs a suite of portable, digital tools that enhance efficiency, accuracy and data management associated with treatment systems, run-off controls and other water quality inspections.
Through ongoing and systematic monitoring and reviews of each operation’s water management processes, Arch’s environmental professionals regularly identify opportunities to protect water resources. This process includes ongoing groundwater and surface water monitoring, proactively diverting flows around the active mining operations, and reducing the footprint of process areas to proactively minimize potential impacts.
Arch and its subsidiaries create valuable water resources on current and former mine lands and actively manage those resources in a way that contributes greatly to a healthy ecosystem.
Extraordinary Compliance Record
compliance rate in 2021
Arch performed over 134,000 water-quality tests without a single exceedance.
Through the application of its Compliance Management System and its sharp focus on water quality management, Arch has achieved an extraordinary compliance record. During the past five years, Arch has tested an average of 270,000 water quality parameters per year at its current and former mining operations, and recorded an average of just two exceedances per year. In 2021, Arch performed over 134,000 water quality tests and didn’t have a single exceedance for a 100 percent compliance rate, despite the frequent occurrence of extreme and fast-moving weather conditions in the mountainous terrain of Appalachia. In 2020, Arch performed over 168,000 water quality tests, and had just one exceedance, which equated to a compliance rate of 99.999 percent. In those rare instances when an exceedance has occurred in recent years, that exceedance has nearly always been minor in nature and has been addressed and promptly brought into compliance.
Compliance Management System
For more than a decade, Arch has been operating in conformance with an EPA-approved Compliance Management System (CMS), modeled after the ISO 14001 Environmental Management System standard. Under our CMS, we require each subsidiary facility to maintain full compliance with all applicable environmental regulations and to monitor that performance in alignment with the “management plan” model of Plan/Do/Check/Act. Each operation regularly reviews its applicable regulatory framework and its environmental operating risks, ranks those risks and mitigates accordingly. Each operation regularly performs self-evaluations of compliance performance, and that performance, and those self-evaluations, are supplemented by corporate environmental compliance audits and third-party audits, undertaken to minimize the risk of noncompliance and environmental harm. The CMS has built-in measures to drive continuous improvement, with emphasis on risk reduction and environmental performance improvement.
Annual environmental improvement plans are developed by each facility and incentives for outstanding environmental compliance performance are awarded. Underpinning the overall environmental program, Arch utilizes an industry-leading environmental management information system (EMIS) to assist in managing and tracking environmental data; compliance obligations; audit findings and corrective actions; and regular internal reporting of environmental activities. Arch continues to build out the capabilities of its EMIS to improve the efficiency of compliance assurance and to reduce risks of environmental harm.
All of our subsidiary mining operations maintain Environmental Management Systems (EMS) that align to ISO 14001:2015. We continue to evaluate the potential future certification of our environmental management systems to conform to the internationally recognized ISO 14001 standard.
Water Conservation and Recycling
Reducing Water Discharge Points
Arch subsidiary operations have invested significant effort in conserving and recycling water to minimize the need to access outside water resources. In 2021, Arch subsidiaries recycled nearly 2 billion gallons of water, thus avoiding drawing a commensurate amount of new gallons from surrounding water sources. These are “gallons avoided” and constitute saving approximately 42 percent of the water that otherwise would have been withdrawn to run Arch’s subsidiary operations. The company continues to explore ways to expand its recycling efforts still further. Through an intense focus on completing robust mine reclamation activities, Arch has eliminated and/or reclaimed over 1,300 discharge points at current and former mining operations since 2015 and currently monitors 650 discharge points. That equates to a reduction of nearly 67 percent of its total discharge points, with the goal of achieving further reductions in coming years.
Beginning with the 2020 operating year, Arch is accounting for its operational water usage according to the guidelines published by the International Council on Mining and Metals as “A Practical Guide to Consistent Water Reporting (2017).” This framework provides methods for quantifying water inputs to a mine’s operation, outputs back to the environment, water consumed by the processes, and recycled water streams, which constitute clean gallons avoided.
2021 Water Usage
Water Accounting
(in millions of gallons, for Arch and its subsidiary operations)*
| Water Withdrawn | Water Recycled |
Total Water Used (Withdrawn + Recycled) |
Water and Wastewater Discharged | Water Consumed |
|---|---|---|---|---|
| 2,658 | 1,935 | 4,593 | 1,374 | 1,006 |
* These numbers are best estimates. Arch continues to refine its data collection and reporting processes, and these numbers will change as the models evolve.
| Surface Water | Groundwater | Municipal Water | Total |
|---|---|---|---|
| 155 (5.8%) | 2,465 (92.8%) | 37 (1.4%) | 2,657 (100%) |
According to the Water Resources Institute website, and based on the fact that all Arch subsidiary operations are within the United States of America, Arch has no operations that are within regions with “high or extremely high baseline water stress,” and therefore zero percent of our water is sourced from regions with “high or extremely high baseline water stress.”
Of all the water recycled and reused by Arch subsidiary operations, 100 percent of that volume is recycled back through the same process at the same facility or through a different process at the same facility. Zero percent is reused by a different Arch subsidiary facility or non-Arch facility.
