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1 yl <br /> III. Comments - Compliance <br /> j <br /> Below are particular issues with regard to any of the compliance items. <br /> Enforcement actions resulting from failure to comply with the Act, Rules <br /> and Regulations, and the permit also are identified below. <br /> i <br /> 1 . Topsoil salvage as required to allow for expansion of the No. 1 <br /> Mine coal storage area appeared to be 90% completed. All available <br /> topsoil (in some areas to a depth of over 61 ) was being salvaged. <br /> 2. Road drainage ditches and culverts were functioning well . No <br /> erosion or road drainage problems were noted despite the fact that a <br /> considerable amount of runoff was entering the road drainage system. <br /> 3. Water was being discharged from the lower sediment pond of the <br /> four pond system below the refuse pile. The ponds collect disturbed <br /> runoff from the preparations plant area and the refuse pile. The _ <br /> discharge water which was entering Coal Creek was a dark grayish-black in <br /> color, apparently due to suspended coal fines. Water entering the <br /> sediment ponds originated from two sources; surface runoff from melting <br /> snow on the refuse pile and prep plant yard area, and overflow discharge <br /> from the wash plant. <br /> A discharge sample taken by Mr. Bowman on the 12th, during the <br /> inspection, indicated a TSS concentration of 1280 mg/l - considerably in <br /> excess of the NPDES limit of 70 mg/l. <br /> The major contributing factor resulting in the high TSS <br /> discharge was the fact that the upper two sediment ponds in the 4 pond <br /> series were completely filled with sediment and were providing no <br /> detention time whatsoever. With the limited settling time provided by <br /> the two functional ponds, the fine suspended solids remained in <br /> suspension and were discharged from the system. <br /> The fact that the upper two sediment ponds had completely <br /> filled with sediment in a relatively short period of time may be <br /> attributable in part to the fact that the slurry pond located at the <br /> preparation plant was full of sediment and wash plant overflow water was <br /> being discharged onto the surface of the prep plant yard area and <br /> diverted directly into the sediment control system. The wash plant water <br /> contains a high concentration of very fine coal particles which may have <br /> directly contributed to the high TSS discharge. Also, the wash plant <br /> water flowing across the yard area would have picked up additional <br /> sediment which was eventually deposited in the sediment ponds, <br /> contributing to the failure of the system. <br />