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Home My WebLink About20210903PAC to PIIC Attach 77-2 Deer Creek Mine Bulkhead & De-watering Chronology.docA chronology of the bulkhead and de-watering pipeline events is summarized below: 2014 Reviewed historic bulkhead installations (failures and successes) Discussed application protocol with MSHA District 9 Price Field Office Designed bulkhead installation based on the National Institute for Occupational Safety and Health (NIOSH) IC 9506 “Guidelines for Permitting, Construction, and Monitoring of Retention Bulkheads in Underground Coal Mines” Developed wells from surface for long term monitoring of bulkheads Prepared draft application 2015 January 6, 2015 - Meeting was held with MSHA District 9 Price Field Office January 20, 2015 - Initial bulkhead submittal. District 9 requests technical assistance from Mine Emergency Operations (MEO) and Mine Waste and Geotechnical Engineering Division (MWGE) March 2, 2015 - Deer Creek Mine receives copy of memorandum from MEO to Russell Riley dated February 23rd outlining deficiencies March 2, 2015 - Deer Creek submits Addendum #1 (add air sampling tubes) to address MEO’s concerns March 12, 2015 - Submitted Addendum #2 (addressing possible impounded water by primary bulkheads) April 1, 2015 - Submitted Addendum #3 (relocation of secondary bulkheads from 1st Right x-28 to 1st Right x-4) April 10, 2015 - Submitted Addendum #4 (re-sequencing mine closure to provide inspection of both sets of bulkheads) May 29, 2015 - Deer Creek received disapproval letter from District 9 with technical reasons for disapproval July 14, 2015 – Submitted Addendum #5 (bulkhead application extensively revised to address concerns of the MSHA Mine Waste and Geotechnical Engineering Division letter dated May 15, 2015) September 8, 2015 – Deer Creek received disapproval letter from District 9 with enclosed August 21, 2015 report by MWGE October, 2015 - PacifiCorp retained J.T. Boyd to conduct a third-party independent review of the Deer Creek Mine closure plan October 1, 2015 - PacifiCorp met with Assistant Deputy Director of Labor to outline concerns with MSHA’s jurisdictional authority related to mine closure December 1, 2015 - received notification from District 9 stating, “We do not have the authority to approve bulkheads for the purposes described” December 18, 2015 - PacifiCorp submits application to UDOGM to construct interlocking parallel plugs and seal enhancement April 12, 2016 - PacifiCorp receives amendment denial from UDOGM: “After spending considerable time reviewing RMP [Rocky Mountain Power] proposed mine closure and particularly the water retention design, the Division, in a routine phone call with Mr. Russell Riley of MSHA on April 11, 2016 was told that his letter of December 1, 2015 had been interpreted incorrectly by you and also by the Division. He emphatically stated that the letter was intended as an unequivocal denial of the plan. He stated that under no circumstances could MSHA approve a water-retaining structure as part of mine closure plan. He asserted that the letter was referring to MSHA's lack of legal authority to approve a plan that requires water retention, not its jurisdictional authority to approve the closure plan. He affirmed that MSHA does have jurisdiction to review and approve mine closure plans and did not waive that jurisdiction for the RMP plan.” After receiving the April 12, 2016 denial from UDOGM for the Interlocking Parallel Plugs application, PacifiCorp coordinated a meeting with parties of interest (BLM, USFS, Emery County, UDOT) to evaluate permitting requirements for the proposed mine relief drainage pipeline from the Rilda Canyon 1st Right Portals to the Huntington Plant Raw Water Pond. PacifiCorp selected the route to minimize potential environmental and infrastructure disturbance: Pipeline corridor would be routed along existing rights-of-way, Emery County 306 and State Highway 31 (within existing previously disturbed boundary) Proposed pipeline corridor minimizes potential impact to archeological resources Proposed route is outside of riparian and wetland resources Huntington River crossings utilize existing bridge structures Directional borings implemented crossing State Highway 31 Mine drainage diverted to Huntington Plant for consumptive use (partially offsets use of Huntington River in plant operations) Pipeline route maintains clearance from existing utility infrastructures (phone, electrical, culinary water lines, natural gas collection systems) Permitting procedure - PacifiCorp committed to do the following: Submit SF-299 forms and Plan-of-Development (POD) to the BLM and USFS Retain an independent third party contractor to assist the federal agencies in preparation of the NEPA document Select an engineering firm to design the pipeline with experience with civil projects Submit road encroachment applications to Emery County and UDOT Request pipeline easements from private property owners Submit application to Division of Water Rights requesting Permanent Change Application for Rilda Canyon and Deer Creek Canyon portals for use in Huntington Plant operations Submit an application to DWQ for additional point source discharge , Deer Creek Mine Outfall (003), to allow for discharging mine water from Rilda Canyon directly to Huntington River outside the USFS /anti-degradation boundary Schedule meetings with UDOGM to discuss mine drainage permitting issues Permitting Process: PacifiCorp submitted SF-299 forms and POD to BLM and USFS - May 11, 2016 PacifiCorp contracted a third party environmental firm Jones & DeMille Engineering to assist the BLM and USFS in preparation of the NEPA document PacifiCorp submitted road encroachment applications UDOT Road Encroachment Permit Submitted May 12, 2016 Approved/Amended November 11, 2016 Emery County Road Encroachment Permit Submitted November 3, 2016 Approved December 21, 2016 PacifiCorp submitted easement requests with private property owners PacifiCorp submitted application to Division of Water Rights requesting Permanent Change Application for Rilda Canyon and Deer Creek Canyon portals for use in Huntington Plant operations Permanent Change Applications approved Permanent Change Application Number 93-1115 (a41873) approved October 25, 2016 Permanent Change Application Number 93-3780 (a41874) approved November 10, 2016 PacifiCorp submitted an application to DWQ for additional point source discharge , Deer Creek Mine Outfall (003), to allow for discharging mine water from Rilda Canyon directly to Huntington River outside the USFS /anti-degradation boundary Submitted September 15, 2016 NEPA Process: Initial NEPA scoping – June 13, 2016 Issues Analyzed in EA Document based on public scoping: Pipeline corridor: Hydrologic issues Potential impacts to wetlands and riparian resources Water quality - acid mine drainage, elevated total iron, total dissolved metals Use of mine water in plant operations Water rights Construction impacts Sediment control and spill control prevention Traffic control Recreational impacts Biological resources Cultural resources Visual resources Environmental Analysis (EA) completed - September 26, 2016 (refer to Appendix E Deer Creek Mine Closure Water Pipeline UTU-91700 and PRI-1606 – Final Environmental Assessment) Draft Record of Decision (ROD) and Finding of No Significant Impact (FONSI) – September 26, 2016 (refer to Appendix E Deer Creek Mine Closure Water Pipeline UTU-91700 and PRI-1606 – Final Environmental Assessment) Public comment periods BLM 30 day comment period September 27 - October 27, 2016 No public comments received USFS 45 day Objection Response September 27 – November 14, 2016 Received objection response from Sierra Club/HEAL Utah July 6, 2017 BLM/USFS approves EA, issues FONSI and Notice-to-Proceed (start construction) July 12, 2017 Start construction, dug test pits for direction drill holes along Highway 31 July 13, 2017 Issued Notice-to-Proceed to Nielson Construction July 17, 2017 Nielson Construction notifies PacifiCorp of scheduling conflict (unable to fulfill contract) August 14, 2017 Approved Non-Compete for W.W. Clyde August 15, 2017 Contract signed with W.W. Clyde August 21,2017 Started directional drilling – Diversion Dam November 2, 2017 W.W. Clyde completed pipeline along Highway 31 November 22, 2017 W.W. Clyde completed pipeline in Rilda Canyon and PacifiCorp property December 1, 2017 Nielson Construction completed pipeline within mine property