2016-06-01_GENERAL DOCUMENTS - C1981035

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County.' We are requesting that the Division enter a cease and desist order, and that this matter be heard by the Mined Land Reclamation Board at its July meeting. Please review the May 11, 2016, letter to me from Carl Mount attached, and consider this background. BACKGROUND On March 21, 2012, GCC's operations were inspected and the company was cited for violations for placing coal mine waste from the King Coal II mine at an unpermitted location at the King Coal I mine and in violation of state -mandated performance standards. A notice of violation was issued on April 5, 2012, and on Aug. 14, 2012, the company submitted a technical revision of its permit. To this day, more than four years later, • GCC has not submitted a complete application for its permit revision; • GCC has not obtained its permit revision; • GCC continues to deposit waste at the King Coal I site; • It is not at all clear that the disposal area being used is adequately designed or constructed to contain contaminants and prevent them from entering ground and surface water. It would certainly never be permitted in this form under current requirements; • Water quality monitoring is very limited and inadequate, despite the fact that historic water sampling below the waste pile showed clear exceedances for lead and cadmium as much as 30 years ago and recent news reports show that toxic lead and mercury are contained in the GCC waste deposits. See attached. • La Plata County has repeatedly indicated a county permit is required for this disposal, though despite the County's repeated assertions that a permit is needed, no county permit has been sought or applied for by GCC; While continued dumping on the site occurs, without adequate monitoring, whatever potential problems already exist are being 1 There are other related Technical Revisions pending as well, notably TR 26.