Laserfiche WebLink
<br />2 <br /> <br />We would like to incorporate WSERC's comments into our letter. <br />A copy of the DMG's response to WSERC's comments on PR-03 is enclosed. <br />We don't think BRL's plan guarantees zero contamination of the North Fork and <br />surrounding area as stated. For example, lining the pond could only be of help. <br />We are not certain whose statement about "zero contamination "your letter refers <br />to. However, permits for coal mines are not required to demonstrate that no <br />pollution will occur as a result of mining. Coal permits must demonstrate that <br />mining and reclamation operations are designed to prevent damage to the <br />hydrologic balance outside the permit area, and those operations must be <br />conducted so as to minimize impacts to the hydrologic balance. This includes <br />protecting waters from adverse effects due to mining and protecting the rights of <br />water users. These regulatory provisions are found in Rule 2.05.6(2) of the coal <br />mining regulations. <br />The DMG is forwarding a few remaining technical adequacy questions regarding <br />protection of the hydrologic balance to BRL in the next few days. Other than <br />these topics, the.'DMG believes the PR-03 application complies with the <br />requirements of Rule 2.05.6(3). <br />Your letter suggested lining the sedimentation pond that is being moved across <br />the road from its present location. This pond will treat storm runoff from portions <br />of the Bowie No. 2 Mine and treated bathouse water. No other water or sources <br />of contaminants are permitted for treatment in the sediment pond. All water <br />discharged from the pond will be required to meet effluent limits in the mine's <br />discharge permit issued by the Colorado Department of Public Health and <br />Environment. Coal mines in several parts of the state have been successfully <br />using similar sedimentation ponds to treat similar waters since the requirements <br />to install these ponds went into effect in 1980. BRL has not identified, and the <br />DMG is not aware of, any adverse impacts to the North Fork or its associated <br />alluvium to be expected from the presence of the proposed sedimentation pond. <br />Therefore, the DMG does not plan to require BRL to line the pond. <br />Another concern was the lack of contingencies for conveyor failure, clean up <br />plans, specifications of conveyor equipment that would insure no increase in <br />noise levels for nearby residents. <br />The DMG does not typically required contingency plans for scenarios such as <br />conveyor failures unless an anticipated failure would cause off-site environmental <br />impacts. The Bowie No. 2 permit includes plans for a series of ditches and <br />