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- , <br />Attn: Kent Gorham, DMG <br />April 11, 1994 -page 2 <br />4. Although Trapper has no data to prove this contention, as flow recorders cannot be used during the <br />winter, it was our observation that neaz record high temperatures in late February and early March cre- <br />ated asituation where snow melted very rapidly off the mine. Because the ground was still frown and <br />impermeable to flowing water, there was an unusually high peak runoff in several drainages including <br />West Pyeatt Gulch. This flow was sufficient to overcome the erosion control structures in place at the <br />West Pyeatt outfall. <br />Notice of Violation C-94-006 also included piping and/or erosion problems noted at Johnson 9R, Johnson lOR <br />and No Name SR ponds. Mr. Gorham was very clear during our discussions on March 3l, that the N.O.V. was <br />no[ being issued as a result of the problems encountered at these locations. Tn fact, Mr. Gorham was awaze of <br />the problems at these sites before his arrival on March 31. Forrest Luke had informed Mr. Gorham of the <br />problems at Johnson lOR and 1Vo Name 5R nearly a month previous. The extent of the problcros was communi- <br />cated and a schedule for repair was discussed and agreed upon. A follow-up letter dated 3/9/94 was submitted <br />to Mr. Gorham (copy enclosed). The piping occurring under the Johnson 9R spillway apron was first discov- <br />ered by Gorham and Luke during the January complete inspection on 1/24/94. It was agreed that no instability <br />was evident as a result of the piping and that Trapper would repair the spillway as soon as ground conditions <br />allowed. There is evidence that the piping under Johnson 9R was likely caused by the burtowing activity of <br />muskrats. The same scenario is possible with the piping under Johnson lOR spillway, although evidence of <br />burtows was not as cleaz cut. <br />We thank you for your wnsideration of this cortespondence. We are working on a technical revision that will <br />include proposed modifications to our spillway designs to prevent reoccurtence of the problems encountered. <br />When the T.R. is approved, we will put together a separate correspondence which includes a remediation plan <br />and schedule for repair of the items noted on N.O.V. C-94-006. If you have any questions or concerns, please <br />contact me. <br />Sincerely, <br />~~~ <br />Fortest V. Luke <br />Manager of Environmental Affairs <br />FVL/Jsb <br />[DM 1UPR11] <br />Encl <br />M. Long, CDMG <br />W. Gordon Peters <br />1.M. Manem <br />File 109.2.3.3 <br />