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<br />DEPARTMENT OF NATURAL RESOURCES <br />Davitl H. Getches, Executive Director <br />MINED LAND RECLAMATION DIVISION <br />DAVID C. SHELTON, Director <br />Richartl D. Lamm <br />Governor <br />DATE: October 6, 1986 <br />T0: David Shelton <br />FROM: Candy Thompson ~~- <br />RE: RESOLUTION OF NOTICE OF VIOLATION N0. C-86-057, NORTH THOMPSON CREEK <br />MINES, ACID MINE DISCHARGE <br />This memo addresses the issues and resolution proposed by Mr. Richard Fanyo in <br />his follow-up to the assessment conference (letter dated September 30, 1986). <br />In this memo I have dealt solely with the resolution of the on-the-ground <br />problems noted in the violation. Jim Pendleton and I have discussed these <br />issues and are in agreement. Although I have opinions on the legal issues <br />raised by Mr. Fanyo, it is riiy hope that resolution of the physical aspects of <br />the problem will lead to resolution of these legal issues. <br />Please refer to Mr. Fanyo's letter as referenced above for format. <br />In paragraph (g) it is proposed that; <br />1) Ground water flows of the B-seam will be separated from the A-seam <br />waters by means of underground seals or dams such that flow from <br />the B-seam workings will not enter into such A-seam workings and, <br />2) so that flow from B-seam will not be part of a discharge from the <br />discharge points permitted in Permit No. CO-~~29599 (NPDES Permit), <br />3) and if necessary such a work plan will be submitted as a review to <br />the Division (numbers added for reference). <br />Points 1 and 3 are desirable and prudent. A5 to Point 2, the operator should <br />be aware that point source discharge from the A-seam workings upon total <br />sealing and closure is not permitted or allowable. The seals as presented to <br />the Division in Figure 4.4.2-1a of the Minor Revision No. 3 and subsequently <br />approved are considered sufficient for the A-seam portal seals at the North <br />Thompson Creek entry and should not have perceptible leakage. For these <br />reasons the wording of the discharge point should be stricken from Point 2. <br />The B-seam entry, used as an integral part of mining by Snowmass Coal is <br />required to be sealed in final reclamation. Because this portal is expected <br />to have hydraulic head behind it, a hydraulic seal is required for placement <br />in the opening. The seal should be designed so as to disallow leakage or flow <br />from the workings to the surface. <br />For the above reasonings a rewrite of Paragraph (g) as follows would qualify <br />as proper abatement of the violation. <br /> <br />423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203 Tel. (303) 866-3567 <br />~ III IIIIIIIIIIIIIIII <br />