2011-09-26_ENFORCEMENT - C1982056 (3)

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From a practical perspective, differentiation and identification of any waste materials incorporated with soils and used as blended backfill in the Deakins Pit would be nearly impossible at this point due to the blending activities. Similarly, given the blending and backfilling that has occurred, it is questionable whether any effective segregation of waste materials from the blended backfill could be accomplished. It is important to note that any coal waste diverted from the Foidel Creek Mine would not represent a potential hazard to surface or ground water since TC has characterized the coal and overburden materials and has documented that they are non -toxic and non acid - producing. Blending of these materials with other suitable soil and overburden materials from the Deakins Pit would further mitigate any potential for water quality impacts. In conversations with Steve Baker, he also indicated that the previous owner of the Pit and adjacent property could verify that the well, which was the subject of the complaint, was never potable, and that he can provide water quality sampling and testing information to confirm that ground water that accumulates in the Pit meets applicable standards. If there is a concern with 3B Enterprises activities under their approved Permit, it would appear that the concern should be resolved between the Minerals Group and 3B Enterprise, as the operator of the Deakins Pit. Division's Response: Based on the fact that the material that has been blended and used as backfill for the pit may or may not be in compliance with the Deakins Pit Mineral Permit, TC will only be responsible for the stockpiled coal material that has yet to be blended and backfilled ( -'250 cy per TC's survey). The material that was utilized as backfill will fall under the jurisdiction of the Minerals Program. TC's response is adequate. 2. Division's initial adequacy comment: Step 2 of the proposed plan states that TC will work with their contractor to load and transport the existing pile of imported material from the Deakins Pit to the Ross Pit, where it will be combined with an existing pile of similar material for further processing. As addressed in No. 1 above, the material at the Deakins Pit includes not only the material that was stockpiled, but also includes the underground development waste material that has been utilized as backfill. Due to the fact that the Ross Pit is not approved to import or stockpile underground development waste or noncoal waste, further importation of the underground development waste cannot be approved at the Ross Pit. The underground development waste at the Deakins Pit and the underground development waste /noncoal waste at the Ross Pit will be required to be segregated separately at each pit, or returned to the Foidel Creek Mine for segregation and approved disposal. Please identify if segregation of material will occur at each site separately or segregation will be conducted at the Foidel Creek Mine. Twentymile Coal Company response: TC's Abatement Plan represents the most practical and expeditious approach for addressing the CDRMS's concerns. The primary reason that TC has recommended that the limited volume (approximately 250cy) of stockpiled material at the Deakins Pit be moved to the Ross Pit, is that this approach will provide for direct control of the