GENERAL37490

• Permit No: C1981041
• IBM Index Class Name: General Documents
• Doc Date: 8/15/2003
• Doc Name: Proposed Decision & Findings of Compliance for SL2
• From: Partial Phase I
• Permit Index Doc Type: Findings
• Media Type: D
• Archive: No

enforcement actions issued to Powderhorn Coal Company prior to transfer of the permit to SCC have
also been properly abated and terminated, and penalty assessments were paid as required. Review of
past monthly inspections indicates that the required environmental monitoring and site maintenance
activities have been conducted in compliance with permit and regulatory requirements, and reclamation to
date has been conducted in accordance with the approved reclamation schedule. The inspection record
shows that maintenance concerns, when noted by the Division in inspection reports, are promptly
addressed by the operator.
Large scale reclamation operations were initiated and completed by SCC during 2002 at the three refuse
disposal areas and the North Portal facilities area. In addition, a new gravity flow minewater discharge
system was installed (Ouffall 016). The 016 Discharge project involved angled drilling into the lowest
elevation of the South Mine workings. The new minewater system was installed to address concerns
identified by DMG with the previous system, which had required periodic monitoring and maintenance
and which posed the potential for uncontrolled discharge onto I-70 in the event of malfunction. The new
system has performed as designed since installation was completed in March 2002.
(2) Surface and ground water monitoring data, and whether pollution of surface or subsurface water is
occurring, the probability of such future pollution and the estimated cost to abate pollution---
Nine sedimentation ponds are in place at the mine to treat disturbed area run-off, and are authorized
under the operator's CDPS discharge permit issued by the Water Quality Control Division. In addition, a
number of small disturbed areas have permit approved small area exemption (SAE) controls such as
berms and silt fencing, small containment sumps, or vegetative cover adequate to control sedimentation.
Two sediment ponds (Pond 4 and Pond 5) and a minewater pond (Pond 12) were eliminated by
reclamation operations at the North Portal facilities area during 2002. Sediment control for the upper
portion of the reclaimed North Portal Facilities Area disturbance is provided by new Pond 13, with
sediment control for a smaller, lower elevation portion of the reclaimed area provided by approved SAE
berms and silt fencing. The sediment ponds discharge very infrequently, and discharges which have
occurred during recent permit terms have been in compliance with applicable discharge standards. SAE
containment sumps located within the North Decline and Cameo Borrow Area-1 reclaimed areas function
effectively and, due to the extent of vegetative cover in those areas they require virtually no maintenance.
Silt fencing functions effectively but typically requires periodic maintenance to repair damage from high
winds and animals.
There are three minewater discharge locations (001, 002, and 016) authorized under the CDPS permit
and the DMG permit for the South Mine, although only the new Site 016 is active, with 001 and 002
constituting an emergency back-up system. Outfall 016 began discharging in April 2002. The discharge
is regularly monitored for compliance with the CDPS permit and monitored annually by the operator to
demonstrate conformance with probable hydrologic consequences (PHC) projections required by the
DMG permit. To date, quality of discharge water has been in compliance with CDPS permit limits (with
one isolated exception) and in conformance with PHC projections, and it is expected that future long term
quantity and quality of discharge will remain within the range observed to date. The noted exception is
that a single extreme value for total iron (11.0 mg/I) in November 2002 exceeded the CDPS permit limit
for daily maximum (7.0 mg/1) and resulted in a 30 day average of 3.72 mg/I, which exceeded the permit
limit of 3.5 mgll. The exceedance was properly reported by the operator to the Water Quality Control
Division (WQCD). The exceedance appears to have been an isolated occurrence; all previous and
subsequent iron sample values from the site are significantly below the standard. There are no apparent
operational changes that might have resulted in the elevated iron level, and the operator concluded in
their report to WQCD that the extreme value was most likely due to improper handling of the sample.
WOCD concurred with this assessment and chose not to pursue an enforcement action. The highest
monthly sample value prior to December 2002 was 0.12 mg/I, and the highest monthly sample from
December 2002 through June 2003 was .13 mg/I.
DMG collected a sample of 016 mine discharge on May 12, 2003, and had the sample run for the annual
full suite list required under the DMG permit. The laboratory parameter values were relatively consistent
Phase I Bond Release 7 August 15, 2003