Laserfiche WebLink
exacerbated; cleaning up groundwater after it is polluted is generally <br />a difficult task if feasible at all. <br />RECOMMENDATIONS <br />After review of this disappointing regulatory record, Mr. Mount in his letter to me <br />makes three primary recommendations for future action, which, summarized, are: <br />1) Stop further placement of uncharacterized coal mine waste in a <br />waste pile that is not designed to contain soluble and water <br />transportable pollutants. (p.3) <br />2) Obtain a full elemental characterization of the waste material. <br />(p•4) <br />3) Require and immediately implement an adequate water <br />monitoring system. (p.4) <br />Please review Mr. Mount's letter for more specific details. <br />We do note that we are dealing with an applicant who has made foot dragging into an <br />art form. La Plata County ordered GCC to get a local land use permit six years ago and it <br />still does not have one. This Technical Revision has been pending four years. GCC is <br />making a mockery of the regulatory process. <br />OUR REQUESTED RELIEF <br />For these reason, we request the following: <br />1) That DRMS issue a cessation order, pursuant to C.R.S. §34-33-123(1) <br />or other agency authority, precluding continuing dumping of King <br />Coal II waste anywhere on the King Coal I site until permit revision is <br />obtained; 2 CCR §407-2-2.08.4(4)(permit revisions may not be <br />implemented before they are approved). <br />2) Require GCC to obtain a full-blown permit revision under DRMS rules; <br />this was never truly a "technical revision" to begin with under state <br />law and agency regulation S.2 Such permit revision should not be <br />2 Under Colorado law, "'[tjechnical revision' means a minor change, including incidental <br />boundary revisions, to the terms or requirements of a permit issued under this article, <br />which change shall not cause a significant alteration in the operator's reclamation plan." <br />C.R.S. § 34-33-103(27). The location, design and environmental protection provisions for <br />