2008-09-26_REVISION - C1982056 (2)

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INTEROFFICE. MEMORANDUM TO: KENT GORHA FROM: JANET BINN SUBJECT: FOIDEL C K M E, 056, MR-230 DATE: 9/26/2008 CC: DAN HERNANDEZ Kent, we have received a MR from Twentymile Coal Company for the Foidel Creek Mine. This MR230 provides updates regarding the emergency mine water discharge. In August 2008 TCC received verbal OK from David Berry to be able to discharge mine water that exceeded the effluent standard at 115, yet continue to meet the water quality standards downstream on Trout Creek at site 1005. David also stated to TCC that they would need to follow up their emergency pumping with a revision that describes how they are managing the mine water, pumping, and piping. This revision is that response. I have reviewed the MR230 application for completes. Since this is dealing with water balances and stream water quality, I would like to request your assistance in reviewing this revision. Concerns that I identified in my review: • Map 16 was not submitted as a part of this revision. The Map 16 that is approved in the permit dates from October 5, 1999. I will ask TCC to provide an update to this map to reflect the current mining conditions. • Revision Map 24 provided with MR230 shows the waterline from FCBH to Pond D inflow to the west of the primary discharge riser. Based on the Map, I have concerns about the proximity of the influent and the potential for short circuiting of the pond. • Page 2.05-87 was submitted with no changes, but it should be renumbered 2.05-88 to insert correctly. • Revised page 2.05-159 states, "Note: The previous calculation and analysis were based on the premise that EC and sulfate standards were applicable for Lower Trout Creek, based on the stream designation for water supply. Subsequent review by the WQCD determined that these standards are not applicable if there is no active water supply useage. So the following information is no longer valid." o There is indeed the Jones Well downstream on Trout Creek. We have a Well permit from WQCD for this well (dated 3/30/1981, first application 6/1/1965). We do not have anything from the well owners stating that they do not use it. We have TCC's verbal and e- mail comment that this well is not used for drinking water. Without further proof and concurrence from CDPH&E I am unwilling to accept TCC's statement that the in-stream standards do not apply. I called the MR complete on 9/26. We will need to make a decision by October 6, 2008. Please provide me your comments prior to Oct. 6`h. Thanks for your help.