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May 23, 2018 C-1980-007/West Elk Mine LDS <br /> <br /> <br />Number of Partial Inspection this Fiscal Year: 8 <br />Number of Complete Inspections this Fiscal Year: 4 <br /> <br /> Page 2 of 13 <br /> <br /> <br />Inspection Topic Summary <br />NOTE: Y=Inspected N=Not Inspected R=Comments Noted V=Violation Issued NA=Not Applicable <br />R - Air Resource Protection <br />N - Availability of Records <br />N - Backfill & Grading <br />N - Excess Spoil and Dev. Waste <br />N - Explosives <br />N - Fish & Wildlife <br />N - Hydrologic Balance <br />R - Gen. Compliance With Mine Plan <br />N - Other <br />R - Processing Waste <br /> <br />N - Roads <br />N - Reclamation Success <br />N - Revegetation <br />N - Subsidence <br />N - Slides and Other Damage <br />R - Support Facilities On-site <br />N - Signs and Markers <br />N - Support Facilities Not On-site <br />N - Special Categories Of Mining <br />N - Topsoil <br /> <br /> <br />COMMENTS <br /> <br />This was a partial inspection by Leigh Simmons and Jason Musick of the Division of Reclamation, <br />Mining and Safety (Division). Mike Peacock and Ty Hiatt of Mountain Coal Company (MCC) each accompanied <br />the inspection at times. The weather was fine and dry. The mine was active. <br />AIR RESOURCE PROTECTION – Rule 4.17: <br /> Prior to the inspection, the Division had received a courtesy copy of a letter sent to Glenda Owens and <br />David Berry of the U.S. Office of Surface Mining Reclamation and Enforcement (OSMRE) by Jeremy Nichols of <br />WildEarth Guardians (WEG), dated May 18, 2018. The letter alleged a violation of the Surface Mining Control <br />and Reclamation Act related to a failure to control fugitive dust emissions from the coal stockpile and included <br />several still photographs and a link to a video clip. Although the Division had not formally been asked to act on <br />the WEG letter at the time, focus was given during the inspection to MCC’s dust control policy and practice. <br />It should be noted that air quality is regulated in Colorado by the Air Pollution Control Division (APCD). <br />The APCD have issued a construction permit (permit no. 09GU1382) which applies to the majority of the mining <br />and processing facilities at the West Elk mine, and includes detailed and specific terms, conditions and control <br />measures. The Division has no Memorandum of Understanding with the APCD, and is not authorized to enforce <br />an APCD permit. As far as the Division is aware, MCC is in full compliance with permit no. 09GU1382. <br />On pages 2.05-101 and -102 of MCC’s Mining Permit Application Packet (PAP) there are several <br />commitments pertaining to air quality which address the requirements of rules 2.05.6(1) and 4.17 (see Attachment <br />A). The PAP commitments include dust control features on conveyors, the rail loadout and transfer points in <br />general; that “water is applied to any active unpaved roadways, parking areas, and refuse disposal area to control <br />dust emissions from these areas, if required, on a seasonal basis”; and that coal stockpiles “are compacted and may <br />be sprayed as necessary to eliminate particulate emissions created during coal handling.” <br />Before and after the inspection the Division’s inspectors met with Jim Miller (General Manager), Weston <br />Norris (Manager of Engineering & Environmental Affairs), Larry Gillenwater (Manager of Surface Operations), <br />Kathy Welt (Environmental Engineer III), Jessica Wilczek (Mine Engineer), Mike Peacock (Mine Engineer), Ty <br />Hiatt (Preparation Plant Manager) and John Poulos (Project Engineer) to discuss dust control at the mine.