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West Elk Mine <br />• East Mains fault and east of the IONE Tailgate entries to provide temporary storage while <br />sufficient pumping and pipeline capacity was constructed to remove the water from the mine. <br />Even after developed the capability to pump the unexpected groundwater inflows to the surface, <br />these flows overwhelmed the hydraulic capacity of the treatment processes in the sedimentation <br />ponds. A complicating factor was that water pumped from the NE Tailgate sump caused <br />"treatabiliry" problems (see previous Mine Water Treatment discussions), To assure the safety of its <br />workforce and to continue with mining operations, it was necessary for MCC to take decisive <br />action. After evaluating many options, MCC concluded that the best alternative was to utilize the <br />previously mined azea as a large, underground sump while exploring additional treatment options. <br />MCC's NPDES pemut for the sedimentation ponds has a stringent daily maximum daily limit for <br />total suspended solids (TSS) of 70 mg/L (35 mg/L on a 30-day average basis). Historically, has <br />met this limit with few exceptions. The sedimentation ponds were designed and operated to <br />accommodate the volume of water that has traditionally been discharged from the mine (i.e., <br />dominated by imported water). With the unprecedented groundwater inflows with the unusual <br />colloid in 1996, MCC experienced considerable difficulty complying with the effluent limit for <br />TSS. In November, 1996, MCC received a letter from the Colorado Water Quality Control <br />Division (CWQCD) which summarized the permit exceedances in 1996 and potential enforcement <br />actions that could be taken if additional exceedances occurred from inflows from the B East Mains <br />fault or the projected extension of the fault in the Box Canyon Mains entries. The only practical <br />way to guarantee that the hydraulic capacity of the system was not exceeded was to create storage <br />capacity. Because surface storage sites with sufficient volume are not available within or near the <br />• mine facilities azea, the in-mine use of the large capacity sumps became mandatory. <br />An important factor in the decision to use the lazge capacity sumps for underground storage is the <br />requirement that must operate the sedimentation ponds to maintain storage capacity for the full run- <br />off volume from the 10-yeaz, 24-hour storm event. Thus, the operational capacity of the ponds to <br />receive lazge mine dischazges is Tess than the physical capacity of the ponds. <br />Compounding the problem of increased inflows to the sedimentation ponds was the presence of an <br />unusual suspended colloid which had not been previously encountered. This colloid did not lend <br />itself to sedimentation utilizing the flocculants/polymers that had historically been effective. <br />Although MCC was successful in treating this colloid by applying heavy doses of alum, this is not a <br />practicable long-term solution due to the lazge volumes of flocculant produced. This colloid <br />appeazs to have been picked up while flowing across the mine floor, or while stored in the NE <br />Tailgate or other sumps where the water is exposed to the coal and parting material. Water quality <br />analysis on samples taken directly from the fault show the water to be of sufficient quality to meet <br />NPDES discharge standazds for the North Fork. <br />In short, MCC concluded that there was no alternative but to utilize the NW Panels sealed sump <br />in 1996 in order to: (1) avoid hydraulic overloading of the treatment facility, (2) maintain the <br />required capacity to store run-off from the 10-year, 24-hour storm event in the ponds, and (3) <br />provide the necessary sedimentation pond residence time to remove the colloids and other <br />constituents to levels that would enable NPDES permit compliance. After the NE and Box <br />• Canyon Panels have been mined, MCC also plans to utilize these mined-out areas as large <br />capacity sumps. <br />2.05-145 Revised November 2004 PR/0 <br />