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Mid-Continent Resources <br /> Response -W.Q.C.D. <br /> RESPONSE #4 <br /> W.Q.C.D. <br /> 4. Within 20 days of issuance of this order, submit to the Division in writing a detailed <br /> explanation of the probable cause of the noncompliance at outfall 016, including <br /> any changes in minewater handling over past practices which could be <br /> responsible for the increased solids loading to the pond system; <br /> Mid-Continent is of the opinion that changes in minewater handling resulted in <br /> increased sediment loading at Discharge Point 016; in addition, prolonged sub-zero <br /> temperatures had the effect of freezing the ponds and thus diminishing their capacity <br /> and effectiveness in settling the sediments. <br /> Minewater Handling <br /> De-watering of the 103 tailgate has been ineffective, resulting in greater volumes of <br /> water at the working face which picked up sediment from the working area. <br /> De-watering of the tailgate area in advance of mining along"the longwall face is <br /> necessary to the mining process. Inability to adequately de-water the tailgate results in <br /> water seeping through the face, and also washing from the tailgate down the length of <br /> the face. This has occurred along the 103 longwall face. <br /> The problem arose due to dissatisfaction of the Mine Safety and Health Administration <br /> (MSHA) with the use by Mid-Continent of electric water pumps. MSHA issued citations <br /> and ordered removal of the pumps. Mid-Continent substituted air pumps which, <br /> however, have proven unreliable and far less effective in de-watering the mine. <br /> In addition, over the course of the past several months, additional water sprays have <br /> been installed in the active, working areas of the mine, as required by MSHA for dust <br /> prevention and control. <br /> MSHA has required installation of water sprays in the intake airway, on belt heads, belt <br /> lines, and installation of water curtains on the faces. The result is an increase of water <br /> in the active working areas during periods of activity; the water settles on the floor and <br /> in draining out of the mine, carries an increased sediment load. <br /> In addition, MSHA now requires the washing of underground equipment, including 40 <br /> shields every shift, and the stageloader every week. Washing the equipment also <br /> contributed to the sediment load draining from the mine. <br /> Weather <br /> It is the opinion of Mid-Continent that freezing of the ponds in the 016 series diminished <br /> capacity to handle sediment load. Prolonged sub-zero temperatures during December <br /> 5 <br />