APPCOR10242 - Laserfiche WebLink

Home Browse Search

.~ .. • ~ • Mr. Fred Matter, P.E. - October 22, 1982 Page 6 The alleged violation at discharge point 1 for September 17, 1981, which amounted to 90 mg/1, was caused by a defect in the riser pipe which is part of the pond's discharge structure. The defect was temporary in nature. The NOV alleges that CYCC has exceeded daily TSS limitations at discharge points 7 and 17 (CYCC Mine 1 Pond F and Mine 2 Pond K, respectively). All of these discharges occurred before con- struction could be completed on these ponds. As set forth above, construction on these two ponds will be completed shortly, and verification will be submitted to you by November 6, 1982. The NOV cites alleged violations regarding daily TSS for discharge points 10, 14 and 15 (CYCC Mine 3 Ponds A, E, and F, respectively). Again, as set forth above, these ponds are all part of CYCC's Mine 3 permit application, currently pending be- fore MLRD, and the ponds may not be constructed until MLRD ap- proves them. CYCC agrees to build the ponds in accordance with the approved designs by the date determined as set forth above. Construction of these ponds should prevent further nonexempt excursions beyond the daily and monthly average limitations for TSS. CYCC is also cited for alleged violations of the total iron daily and monthly average figures regarding discharge points 2, 7, 14, and 17. As Jeff Saunders explained at the meeting on October 12, the water at these mines, as is the case generally with water in the western United States, is naturally alkaline. Under these conditions, most of the total iron contained in a given sample of water will be in a precipitated state rather than dissolved. Thus, a high total iron figure will almost always be accompanied by a high TSS figure. This is borne out by the data provided the Division by CYCC: every time a violation ie cited for high total iron, a violation for high TSS is also cited. it is therefore submitted that a separate citation for high iron and high TSS is unjustified.' At moat, they should be treated as one violation, because a major component of the high TSS is the particulate iron. In any case, the alleged violation occurring at discharge point 2 for the daily figure, and at that discharge point for the monthly average for March, 1982, is exempt because of the storm exemption of the Permit, quoted above. See the information on Exhibit 5. The other violations asserted for total iron (discharge points 7, 14 and 17) are all subject to the comments set forth