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3 <br />III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made <br />during the inspection. Comments also describe any enforcement actions taken during the <br />inspection and the facts or evidence supporting the enforcement action. <br />Mine Water Discharges <br />Mine water discharge points 001, 002, and 004 were observed on the <br />afternoon of October 2. There was no discharge at 001. 002 was <br />discharging at a rate of 70 gpm, and appeared to be quite clear. <br />The operator recorded a pH of 8.2, conductivity of 2400 micro-mos, <br />and temperature of 72 deg. F. <br />Point 004, where minewater from the North Portal mine workings is <br />discharged into the Coal Canyon drainage, has exceeded total <br />suspended solids (TSS) discharge standards on several occasions <br />over the past year, and to abate this problem, routing of water <br />within the mine has been altered to increase settling time within <br />underground sumps. Discharge observed on the afternoon of October <br />1 appeared to be quite clear, however discharge observed the <br />afternoon of October 2 had a cloudy, brownish appearance. On both <br />days, Coal Canyon drainage above the discharge point was dry, so <br />water observed in the drainage originated from the minewater <br />discharge. Mr. Reschke indicated that the discharge had appeared <br />similar to this on several other occasions during the last month or <br />so, and he speculated that the TSS level was probably around 30 <br />mg/1. The discharge at this site exhibits surges of approximately <br />250 gpm lasting several minutes separated by brief intervals of no <br />discharge. Neither the operator nor I had sample bottles when the <br />discharge was first observed, but we immediately returned to the <br />mine office where he obtained sample bottles from his office and I <br />from my vehicle. We arrived back at the discharge site at <br />approximately 14:20. The discharge was nearing the end of one of <br />the surge periods, but the water had the same cloudy, brownish <br />appearance. Both Mr. Reschke and I obtained samples from the <br />discharge pipe outflow. Water in the sample bottles had a light <br />brown color. I labeled my sample 04110296A, and took several <br />photos at the site. The operator measured pH of 8.7, conductivity <br />of 2800, and temp. of 65 deg. F. There was no sulfurous odor <br />(which had been noted in a recent inspection) at the discharge <br />site. I delivered my sample to Grand Junction Labs at <br />approximately 16:45 for TSS analysis. <br />An enforcement action will be taken if the TSS level exceeds the 70 <br />mg/1 discharge standard. Abatement would most likely include the <br />requirement to pump minewater from this location to a surface <br />settling pond prior to discharge. Potentially suitable sites in <br />the vicinity would include a former sewage treatment pond, and <br />Sediment Pond 4, which is substantially oversized. <br />It was noted on leaving the site that there was no visible plume of <br />