1989-11-27_GENERAL DOCUMENTS - C1981017

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Mr. Robert Hagen, AFO Director - 2 - November 27 , 1989 Issue 2. This is an alleged violation of Rule 4.05.2(1 ) in regard to amp ouse yard and French drain on Sutey Waste Pile." The citation of the lamphouse yard is general . Generally speaking, the tunnel pad pond is provided to accept drainage from the lamphouse yard and is approved for discharge by the mine 's CPDES Permit. Both it and the ditch draining the yard appeared to the Division's representative to be functioning adequately at the time of inspection. There is no evidence that drainage from the area was not passing thru the pond. As for the French drain at the Sutey Waste Pile, this is approved as a surface water monitoring site for the mine. The flow has entered Coal Creek without passing thru a sediment pond or being subject to the mines CPDES permit. This is considered a permit defect by the Division, and the operator will be required to submit by December 15 , 1989 , a technical revision providing an acceptable means of treatment for this water before discharge into Coal Creek . Such a submittal should allow approval by late February 1990. Implementation, however, may not occur until later in the year depending on weather and the nature of the system proposed. In that there is a sedimentation pond and surface water control system present and functioning adequately to collect and treat drainage from the lamphouse yard and no evidence that the drainage does not pass through the pond there is no violation of the rule cited. As for the Sutey underdrain, this is the result of operations being in compliance with a defective permit. Actions are being taken to correct the defect and are authorized by the state program. Issue 3. This is an alleged violation of Rule 4.05 .13(1 ) (a) involving "3rd Quarter GW-1 ." Monitoring of well GW-1 is conducted semi-annually, (Chapter IV, page 23 of the permit package) not quarterly. Since the operator has not failed as yet to meet the monitoring requirements of his approved permit, there is no violation of the cited rule. Issue 4. This is an alleged violation of Rule 4.05.1 (4) (b) by "glory hole bench—drainage to floc pond." The rule cited requires conduct of operations to minimize water pollution and suggests acceptable practices to do so. These practices , while not specifically including sediment ponds, also do not exclude such measures. The Division considers water pollution to occur if water leaves the permit area and does not meet discharge standards. So far as can be determined, this does not happen. The drainage is controlled by the slurry pond (presumably the "floc pond" cited), a treatment facility, and discharge from this pond, which is allowed by CPDES permit, must meet limits specified in that permit. This does not constitute water pollution. Consequently, the operator has taken acceptable measures to control and minimize water pollution as regards all drainage to the slurry pond. There is no violation of the rule cited.