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4.05.2(1), the production mine water discharge does not have to be routed through a sedunentation <br />pond or other treatment facility. <br />4) Immediately on discovery of the production mine water discharge (discharge occurred during the <br />night shift on Monday/Tuesday May 2/3 prior to the inspection on Tuesday morning May 3rc1), TCC <br />closed valves underground to eliminate the discharge source. On Tuesday morning, a manual ball <br />valve was welded onto the accumulator pipe and closed to assure that any further potential for <br />discharge was elinunated. Discussions with mine operations management confirmed that there are no <br />other known locations where a mine water system pressure spike could result in production mine <br />water discharge. Dependent on the results of discussions with the Roll-Seal manufacturer, TCC may <br />replace the manual ball valve on the accumulator pipe with afail-safe flow valve that would remain <br />open to allow air flow but would close under fluid flow conditions, or some other type of valve that <br />would provide positive protection against any future production mine water discharge. <br />5} The next day after the inspection, Jeny Nettleton walked and examined areas downgradient of the <br />NW Mains Ventilation Fan faciliry SAE for any evidence of discharge to Fish Creek No evidence of <br />discharge (muddy, wet, or flowing channels) to Fish Creek from the production mine water discharge <br />or exceedance of SAE design capacirywas observed <br />Relative to Part 2: <br />Key considerations and details relative to the observed water pumping activity at the 18-Right Ventilation <br />Shaft site include: <br />1) TCC holds extensive water rights on both Fish Creek and its tnbutary drainages. The observed water <br />pumping, withdrawal, and beneficial use was being conducted under these existing water rights. <br />The pump being used was a small portable gasoline-powered pump being used on a temporary basis <br />to supply supplemental water at a rate of less than 180 gpm for dilution of drilling fluids in <br />conjunction with the permitted shaft drilling operations. This activity was no different than typical <br />irrigation or stock watering operations in the area, which TCC would be entitled to perform under <br />their existing water rights, and does not represent an actual or potential adverse environmental impact. <br />2) The regulatory section for Part 2 referenced in the NOV (Rule 2.05.3(3)) requires; "A description, <br />plans, and drawings, descnbing the location, construction, modification, use, maintenance, and <br />removal of mine support facilities in the pemmt area including all buildings, structures, utility corridors <br />and other support facilities including but not limited to those listed in 4.04." Rule 4.04 identifies <br />support facilities as, ".., including, but not limited to, mine buildings, coal loading facilities, fan <br />buildings, hoist buildings, preparation plants, sheds, shops, other buildings, railroad loops, spurs, <br />sidings, surface conveyor systems, chutes, aerial tramways, or other transportation facilities... ". The <br />support facilities descnbed in the two cross-referenced regulatory sections are buildings and other <br />substantial engineered structures. The referenced regulatory sections provide no reasonable indication <br />that small temporary support equipment, such as a portable pump, should or needs to be addressed in <br />the permit as "support facilities". <br />Given the above considerations, TCC submits that Rule 2.05.3(3) is not applicable to small, temporary <br />support equipment and respectfully requests that Part 2 of the NOV be vacated <br />NOV CV-2005-006 4 6/3/2005 <br />