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L <br />l~ Cyprus Nvmpa vauey Coal Caporadon <br />An A7lIINfI of Lyqu/ MImn4 ComplM' <br />it October 1989 <br />Pat Nelson <br />Colorado Department of Health <br />Water Quality Control Division <br />4210 East 11th Avenue <br />Denver, Colorado 80220 <br />20.787 Routt Counh RoIC IZ7 <br />01k CnNk, CO 80187 <br />Pltom (~ 879 780D <br />RE: Materials Containment Plan for the Colorado <br />wastewater Discharge Permit System Number Co-^^^~-c"^'o3, <br />Twentymile Coal Company; Foidel Creek Mine CP~}2IL1 <br />• <br />n <br />U <br />Dear Ms. Nelson: <br />As required by Part I.E.1 of the recently issued CO-004261 <br />permit, Twentymile Coal Company is to submit a Materials <br />Containment Plan. Due to the inherent characteristics of the <br />material used at the dewatering facility, the nominal amount <br />stored, and because of the travel route of any spilled <br />material, Twentymile Coal Company respectfully requests an <br />exemption from this requirement. <br />The Materials Containment Plan is to address the prevention <br />and containment of spills of materials used at the site which <br />would have a probability of having a visible or otherwise <br />detrimental impact on waters of the state. The only material <br />used at the dewatering facility is a coagulant, Enact 7883 <br />Liquid, which is manufactured by NALCO. As indicated by the <br />Material Safety Data Sheets (MSDS) which were submitted with <br />the original application, ENACT 7883 is a non-hazardous <br />material. Its constituents would not be regulated by CERCLA <br />or SARA and any waste generated from the spill of the product <br />would not meet the criteria of RCRA. - <br />At a given time, no more than three (3) full 55 gallon drums <br />of Enact 7883 will be stored at the site. The drums are kept <br />in a small, cemented floor building which is located to the <br />east of the dewatering wells and Fish Creek. If a spill was <br />to occur, the material would need to travel over 400 feet to <br />reach Fish Creek. The route of the spilled material would <br />involve moving in three different directions with two abrupt <br />turns before it would reach Fish Creek. Because of the <br />quantity of material and the path a spill would need to <br />follow to reach the creek, it is unlikely the spilled <br />material would reach Fish Creek. <br />c~~us <br />