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<br />• -z- • <br />in the NOV that "water heavily laden with sediment was being discharged <br />from the pond" is not supported by these facts. <br />2. The NOV also states that Dorchester had "failed to adequately maintain <br />sediment pond #1 to insure compliance with performance standards of <br />4,05.6 and protection of the following hydrologic balance". Sediment <br />pond maintenance has been the subject of numerous conversations with <br />Carol Russell of your office. As a result of those conversations, <br />- - Dorchester has been cleaning sediment from sediment pond #1 on a daily <br />basis for several months. <br />Dorchester maintains up to date logs of equipment and personnel allocation <br />to each ongoing project at the mine. We have attached a summary of those <br />logs for the sediment pond maintenance program showing the type of equip- <br />ment and its actual use, the number of personnel assigned to the project <br />and the actual number of hours spent in pond maintenance/cleanout. The <br />attached summaries date back to March, 1982 and are current to May 18, <br />1982. The nine days left blank on the summary sheets are the result of <br />misfiling of the original logs for those days. The pond was maintained <br />on each of those days in a manner similar to the remaining days on the <br />list. <br />As the attached sheets demonstrate, Dorchester has adhered to a daily pond <br />_ maintenance schedule and has allocated substantial amounts of manpower and <br />equipment over the past few months to the cleanout/maintenance program. <br />In addition, it should be noted that 17 hours of equipment time and 24 <br />hours of manpower were utilized in sediment pond maintenance on the day <br />of the inspection. We would suggest that the attached records reveal <br />a concentrated deliberate program of daily sediment removal and main- <br />tenance of sediment pond #1. <br />3. The NOV requires submission of an "adequate, certified design for pond <br />#1 ... within 60 days". As you know, Dorchester is in the process of <br />repermitting the Dorchester #1 Mine under the new permanent program. <br />In late March, 1982, Dorchester submitted a two volume adequacy response <br />to your office. Design calculations for sediment pond #1 as well as a <br />water routing diagram (requested by Carol Russell in her March inspec- <br />tion report) were included in that package. As of the date of this <br />letter, we have not received any comments from the CMLR technical staff <br />regarding the merits of the design calculations. In this light, we <br />feel it is inappropriate for Ch1LR to demand such information .through <br />the enforcement process, particularly when the deficiencies (if any) <br />in the design now on file with your agency have not been transmitted <br />to Dorchester. <br />In conclusion, we feel that the information included herein clearly demon- <br />strates that Dorchester has been diligent in both the ongoing maintenance <br />of pond #1 as well as its attempts to get the pond designed to CMLR's <br />specifications. The water quality analyses Indicated that the present <br /> <br />