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.~ <br />Miscellaneous Findings <br />Mid-Term Permit Review: <br />The following comments pertain to the information contained in the Mid-Term Permit Review, <br />dated April 2, 1997: <br />page 1 In the third paragraph, DMG states that variances to AOC and Cunternporaneous <br />Reclamation must be reviewed by lire Division during mid-term reviews. Although <br />variances should have bern required to approve the two fill structures, no discussion was <br />found in the mid-term review document that indicate the variances were reevaluated. <br />page 4The following statement is made in the first paragraph, "It is assumed that other "~: <br />stipulations issued over the life of this operation have been complied with or terminated <br />after review of various files and documents maintained for this permit." Apparently, this <br />assumption had to be made because adequate documentation is not being provided in the <br />project files. <br />page 6In the discussion ofNOV C-94-020, DMG mentions that a fine was imposed on the <br />operator for failing to dispose of non-coal waste in a non-coal waste disposal area, but no <br />discussion of how this issue was resolved was found in the permit document. <br />page 7From item 7, 1 conclude that disturbed areas and the Jatrs uCdisturbance have not been <br />adequately identified in the permit. During our review of the DWP structure, Kent <br />Gorham suggested that there was pre-law disturbance at the sift, but he was not sure <br />where the boundaries were between pre-law and post-law disturbance. Not only are <br />disturbance boundaries important to effectively regulate mining operations but also such <br />information is needed to determine the reclamation liability upon which to hose the bond <br />amount. (Also see item 32 for additional information that suggests the bond amount could <br />be based on out-of--date or incomplete information.) <br />page L I Items 34, which discusses the need for additional design information, raises two <br />concerns that I believe could be serious oversights. F'vst, it appears that DMG is not <br />requiring certified engineered designs that verify compliance with the State program or <br />generally accepted engineering practices. Second, the as-built certifications submitted by <br />the mine operator do not verify that construction was in conformance with specific permit <br />documents. <br />Conclusions <br />Based on the OSM inspection report, DMG was found to be regulating the New Elk mining <br />S /E ~'90I87.E86 -W c n utnn rr~ rc_o~_~ ,,, ~,.,~ <br />