_ENFORCEMENT - C1981017 ‎(5)‎

• Permit No: C1981017
• IBM Index Class Name: Enforcement
• Doc Name: Bid Documents ‎(IMP)‎ TDN X-90-02-370-001- TV2
• Media Type: D
• Archive: No

Mr. Dan Mathews 2
some reason; (3) this revision was developed because of the past history
of effluent limitation noncompliance or indications thereof; and (4) the
intent of the revision is to lessen the burden of the ponds by
encouraging settling prior to the mine water entering the sedimentation
ponds.
The TDN cited the nature of the violation as failure to prevent to the
extent possible additional contributions of sediment to streamflow and
the location as the pond No. 016 discharge to Dutch Creek.
Because the mine water discharge will no longer be coming from pond
No. 016 and will not be entering Dutch Creek, AFO finds MLRD's response
to be appropriate.
However, the essence of the revision addresses the concerns of effluent
limitations only and not the prevention of additional contributions to
Coal Creek. AFO has concerns that this revision in itself may not
adequately address the design, construction, and maintenance requirement
for best technology currently available for the prevention of additional
contributions to Coal Creek. MLRD may wish to review this revision for
adequacy in preventing additional contributions in Coal Creek and Dutch
Creek or any other receiving stream that may receive the mine water
discharge. This condition will be reviewed by OSM during the next
oversight inspection to ensure compliance with the cited regulation.
MLRD also requested that AFO meet with them concerning this
interpretation of the regulations. AFO agrees that a meeting would be
helpful and will contact MLRD to arrange one in the near future.
Sincerely,
�c� o
Robert H. Hagen, tor
Albuquerque Fi d Of ice