ENFORCE37735

• Permit No: C1982056
• IBM Index Class Name: Enforcement
• Doc Date: 2/8/2007
• Doc Name: Abatement Completion Report for Abatement 10 and 11
• Violation No.: CV2006006
• Media Type: D
• Archive: No

Summary of Abatement Measures
• In order to address potential impacts of the accidental dischazge of coal fines from Pond E and achieve
effective abatement under the associated Notice of Violation (NOV) in a timely manner, specific
abatement steps were identified by the Colorado Division of Reclamation, Mining, and Safety
(CDRMS) in the original NOV and subsequent modifications. Twentymile Coal Company (TCC) has
worked closely with the CDRMS, and other jurisdictional agencies, to proceed with and complete
necessary control, mitigation, and clean-up measures, consistent with the specified Abatement steps, in
a timely manner. The following summarize abatement approach, and document completion and
abatement dates for all specified abatement steps:
Sten 1: Cease discharge of Thickener underflow to Sedimentation Pond E (09/13/061
Immediately on notification of the discharge, a Surface Crew was dispatched to Pond E to seal
the riser by wrapping it with brattice cloth to stop further discharge of coal fines to Foidel Creek.
Dischazge ceased shortly after the coal fines dischazge was discovered (prior to noon on 09/11/06), as
documented by field observations by the CDRMS Inspector (CDRMS Inspection Report attached for
reference). Abated 09/13/06.
Steu 2: Reaair the Thickener underflow oiae (09/13/06)
The thickener pipe was repaired later the same day (09/11/06), as documented by field
observations by the CDRMS Inspector. Abated 09/13/06.
Stea 3: Perform immediate damage control activities on Foidel Creek (09/13/061
Simultaneously with dispatch of a Surface Crew to seal the riser, Environmental Staff proceeded
• downstream on Foidel Creek to determine the limits of downstream migration of coal fines with
normal low-flows in the stream, placing anchored booms at six downstream locations in the
stream to filter and capture coal fines to prevent further migration. Coal fines had been carried
downstream approximately 2.8 miles by normal streamflows to a marshy azea in the vicinity of a road
crossing of the rail-line behind the original Ashley Ranch house. There was no fiuther evidence of
coal fines migation below this point (based on visual turbidity observations). These activities were
performed immediately after notification of the coal fines dischazge on 09/11/06, as documented in my
e-mail of 09/12/06 and confinned by field observations by the CDRMS Inspector. Abated 09/13/06.
Sten 4: Notify the CDPHE-WOOD, CDOW, and USACE of this event (09/13/061
These agencies were notified by phone on 09/12/06, with copies of follow-up communications
provided to the CDRMS. A representative of CDOW visited the site on 09/14/06. Abated 09/13/06.
Step 5: Notify downstream users, from the noint of discharge from Sedimentation Pond E to the
confluence of Trout Creek with the Yamna River, of the un-aermitted discharge, and
demonstrate to the Division such notification (09/29/061
As a courtesy, known downstream water users were contacted by phone on 09/18/06 and
09/19/06. Based on a list of downstream water owners/users provided by the CDWR on 09/19/06,
8 of the 9 identified water owners/users had already been contacted by phone. A follow-up
notification letter was sent to the identified water owners/users, as well as the Routt County
Environmental Health Department and Town of Hayden, by registered mail, on the same date.
Copies of registered mail receipts (attached) were provided to the CDRMS. Abated 09/22/06.Steo 6
•
NOV CV-2006-006 Abatement Report 4 2/7/2007