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S. S. Shuey -3- February 23, 1994 <br />------------------------------------------------------------------ <br />------------------------------------------------------------------ <br />Auq. 1992: A 1.5 million gallon sump was developed in the B-Seam. <br />Nov. 1992: A chemical treatment system was installed using Nalco <br />92DR043 Clarification Aid to reduce the required <br />settling time which did improve water clarity. <br />Dec. 1992: A second chemical, Nalco 9810 flocculent, was added to <br />the chemical treatment system to work in conjunction <br />with the 92DR043 to further enhance the chemical <br />treatment. <br />Mar. 1993: The water/chemical interface point was moved <br />approximately 300 feet closer to the main sump to <br />prevent breakage of the flocculent chain which <br />improved the overall effectiveness of the <br />clarification aids. <br />The cause of the violation was apparently the ineffectiveness of the <br />chemical treatment system. This violation is not the result of the <br />unwarranted (unjustified) failure of Somerset to comply with the <br />Rules. Somerset recognized the potential problem and took actions to <br />mitigate the problem. One water treatment system failure could hardly <br />be considered unwarranted. <br />NOV C-93-068 ISSUED 04-28-93 <br />This violation was issued for failure to construct and maintain the <br />drainage control system around the gob pile. Prior to this violation <br />Somerset had recently worked the gob pile and had improved the road <br />into the gob pile. However, the ditches along the top of the gob pile <br />and along the road leading to the gob pile had not been re- <br />established. The gob pile is within the site sedimentation control <br />system, therefore a failure of the gob pile drainage system would not <br />be a catastrophic event. This violation is not the result of the <br />unwarranted (unjustified) failure of Somerset to comply with the <br />Rules. The occasional lack of maintenance or diligence in cleaning <br />ditches is not considered unwarranted. <br />NOV C-93-117 ISSUED 08-02-93 <br />This violation was issued for failure to maintain sedimentation <br />control. In two places berms were not maintained so run-off by-passed <br />alternative sediment control structures. No run-off left the site. <br />Somerset acknowledges that this violation resulted from a lack of site <br />maintenance. This violation is not the result of the unwarranted <br />(unjustified) failure of Somerset to comply with the Rules. The <br />occasional lack of maintenance is not considered unwarranted. <br />NOV C-93-118 ISSUED 08-02-93 <br />This violation was issued for failure to follow the surface blasting <br />rules. In this case the surface superintendent, not being familiar <br />with the Rules, used a quarter to a half of a stick of dynamite to <br />break a large boulder that was taking up space in the gob pile. <br />