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NI <br />1111 ENERGY <br />Twentymile Coal, LLC <br />Mr. Jared Ebert, Environmental Protection Specialist <br />Division of Reclamation, Mining, and Safety <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />("303) 866-3567 X 8120 <br />REGelvev <br />MQ� 12016 <br />of Rec1 ie�N`on' <br />pivisM nm9 & Sa <br />�15 Routt County Road 27 <br />Oak Creek, CO 80467 <br />970.879.3800 <br />May 25, 2016 <br />RE: Twentymile Coal, LLC - Foidel Creek Mine (Permit No. C-82-056), Minor Revision <br />(MR16-297) — Fish Creek Borehole Coal Fines Cleanup and Remediation <br />Dear Mr. Ebert: <br />Twentymile Coal_ LI_.0 (TC) requests CDRMS approval of a Minor Revision to our existing approved <br />Permit to address cleanup of a localized discharge of coal fines, expansion of the disturbed area to <br />include areas affected by the discharge and related cleanup activities, and related remediation and <br />reclamation activities. The proposed activities and this permitting action are components of the <br />required abatement measures for Notice of Violation (NOV) CV -2016-001. <br />TC currently withdraws mine water from two boreholes at the Fish Creek Water Treatment location <br />both to maintain the level of accumulated water in underground mine pools below a pre -determined <br />elevation and as part of TC's overall mine water recycling program to provide feed -water for ongoing <br />mining and processing operations. One of the Fish Creek boreholes had not been used in some time, <br />and the pump was started -up to flush the system in preparation for subsequent use. Unfortunately, <br />si`,nificant coal fines had accumulated in the underground sump, which were re -suspended when the <br />pump was started back up. The quantity of coal fines resulted in an obstruction in the discharge pipe at <br />the surface causing one of the -pipe joints at the well -head to fail. The water/coal mixture built-up in <br />the vertical culvert around the well -head and overflowed, with the coal fines slurry flowing under the <br />existing snow -cover before the leak was discovered and the pump was shut-off. <br />Based on the time the pump had been operating and an initial visual inspection, it appeared that the <br />discharge volume was limited and any deposition of coal fines was confined to the immediate area of <br />the well -head and an upper bench area. Given extensive snow -cover, it was not possible to assess the <br />full extent of any further movement of the coal fines at the time. Once the snow melted this spring, it <br />was discovered that the coal fines had moved further than originally thought, and TC placed wattles <br />just beyond the limit of the visible coal fines to prevent them from moving any further, with the intent <br />of cleaning up any coal fines deposition once the ground dried -out. <br />Consistent with both our original intent. and applicable NOV abatement requirements, TC proposes to <br />cleanup any significant accumulation of coal fines which could adversely impact vegetative growth or <br />which represents a reasonable potential source for sediments which could affect runoff water quality. <br />As noted in the CDRMS May 2016 Inspection Report, "A portion of the fines southwest of the FC <br />Pump CMP affected an area on a steep slope that is heavily vegetated with shrubs and grass. The <br />fines in this area are very light and do not appear to be impacting the plant growth. To the northwest <br />o f the FC Pump CMP, the fines collected in a low spot in the topography and are several inches <br />deep.". Given this observation and assessment, TC proposes to remove any significant coal fines <br />