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2011-09-22_ENFORCEMENT - C1982056 (6)
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2011-09-22_ENFORCEMENT - C1982056 (6)
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Last modified
8/24/2016 4:43:19 PM
Creation date
9/26/2011 7:53:24 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1982056
IBM Index Class Name
ENFORCEMENT
Doc Date
9/22/2011
Doc Name
Adequacy Responses for Abatement Plan Recieved Via- Email
From
Jerry Nettleton
To
DRMS
Violation No.
CV2011005
Email Name
JDM
Media Type
D
Archive
No
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materials with other suitable soil and overburden materials from the Deakins Pit would further mitigate <br />any potential for water quality impacts. In conversations with Steve Baker, he also indicated that the <br />previous owner of the Pit and adjacent property could verify that the well, which was the subject of the <br />complaint, was never potable, and that he can provide water quality sampling and testing information <br />to confirm that ground water that accumulates in the Pit meets applicable standards. <br />If there is a concern with 3B Enterprises activities under their approved Permit, it would appear that <br />the concern should be resolved between the Minerals Group and 3B Enterprise, as the operator of the <br />Deakins Pit. <br />2) Step 2 of the propoed plan states that TC will work with their contractor to load and transport the <br />existing pile of imported material from the Deakins Pit to the Ross Pit, where it will be combined with <br />an existing pile of similar material for further processing. As addressed in No. 1 above, the material <br />at the Deakins Pit includes not only the material that was stockpiled, but also includes the <br />underground development waste material that has been utilized as backfill. <br />Due to the fact that the Ross Pit is not approved to import underground development waste or noncoal <br />waste, further importation of the underground development waste cannot be approved at the Ross Pit. <br />The underground development waste at the Deakins Pit and the underground development waste at the <br />Ross Pit will be required to be segregated separately at each pit, or returned to the Foidel Creek Mine <br />for segregation and disposal. Please identify if segregation of material will occur at each site <br />separately or segregation will be conducted at the Foidel Creek Mine. <br />Response: TC's Abatement Plan represents the most practical and expeditious approach for <br />addressing the CDRMS's concerns. The primary reason that TC has recommended that the limited <br />volume (approximately 250cy) of stockpiled material at the Deakins Pit be moved to the Ross Pit, is <br />that this approach will provide for direct control of the segregation process and more efficient <br />segregation of the material with the screening equipment that will be rented and temporarily installed <br />at the Ross Pit. <br />TC accepts the Minerals Group's assertion that the Ross Pit may not be permitted for importation of <br />waste materials, however, the major portion of the material of concern is currently located in this Pit, <br />and the addition of the minor volume currently stockpiled at the Deakins Pit would have negiligible <br />effect, and would allow for more effective and efficient processing and disposal of this material. <br />As noted in TC's proposed Abatement Plan and the accompanying transmittal letter, it is TC's desire <br />and intent to proceed in a timely and responsible manner to address the CDRMS's concerns. Given the <br />responses presented above, we submit that the Abatement Plan, as submitted, represents the best and <br />most practical approach to accomplishing this objective. <br />Best regards, <br />Jerry M. Nettleton <br />
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