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Fred R. Banta, Director August 10, 1990 <br /> MLRD, Denver, CO 80203 Page 8 <br /> conveyor belt spilling below the belt where a small-area exemption <br /> had been granted. " <br /> As an abatement step of NoV C-89-003, Mid-Continent was <br /> required to "submit a plan . . . to improve the present system of <br /> mine water treatment. " As a part of this plan, Mid-Continent <br /> embarked on a program of testing methods of reducing the sediment <br /> load from the mine discharge to the Outfall No. 016 ponds, but had <br /> reported to MLRD that nothing satisfactory had been developed. <br /> The Company continued to seek feasible treatment <br /> alternatives, specifically to prevent a repeat of the prior <br /> difficulties with the ponds. In doing so, the Company was acting <br /> in good faith and to honor commitments made to MLRD. <br /> Mid-Continent submitted a letter to MLRD, dated June 14, <br /> 1989, with the following explanation of what occurred and had led <br /> to issuance of NoV C-89-013 . <br /> Due to the problem we experienced last winter at <br /> the tunnel ponds, Mid-Continent has made a concerted <br /> effort to reduce the turbidity of the water coming <br /> from the mine through the tunnel. <br /> In one area of the tunnel we had determined that <br /> it would be feasible to pump turbid water from the <br /> floor onto the overland coal conveyor belt. The <br /> coal on the conveyor is sprayed repeatedly with <br /> water for dust suppression purposes, and we reasoned <br /> that some additional turbid water would be easily <br /> handled. It seemed a good way to reduce the <br /> sediment load to the tunnel ponds. <br /> Unfortunately, the addition of more water caused <br /> the coal to spill from the belt as it travelled <br /> overland. This occurrence is unprecedented in the <br /> time since the tunnel system became operational. <br /> Mid-Continent immediately suspended the practice of putting <br /> mine discharge water on the belt upon discovering the spillage. <br /> Subsequently, the Company installed an 8-inch, buried polyethylene <br /> pipeline to accomplish the same purpose, namely, a means to route <br /> turbid mine discharge water to the coal preparation plant. <br /> Given the problems which had occurred previously with the <br />