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<br />f <br />Mountain Coal Company <br />P.O. Box 591 <br />Somerset, CO 8 (434 <br />970-929-5019 <br />C-80-007 <br />West Elk Mine <br />Complete inspection <br />5/11/99 <br />Mitch Rollings, 370, OSM <br />Joe Wilcox, OSM <br />Larry Routten, DMG <br />Jim Burnell, DMG <br />Henry Bazbi, West Elk <br />Christine Johnston <br />This inspection was started in October 1998. Because of conditions observed during that <br />inspection, I requested an OSM hydrologist review prior to completion of the inspection. Snow <br />pack delayed the conclusion of the inspection until late spring after snow melt. <br />DMG issued a Notice of Violation (NOV) as a result of this inspection. C-99-005 was issued for <br />violations of 2.07.7(3)(a) and 2.07.7(8) of the approved Colorado program at the shaft 3 area of <br />the mine. A small area exemption (SAE) had been approved for this area based on information <br />provided b}' West Elk. It was found that West Elk had 1.) submitted a faulty SEDCAD run <br />(transposed number) that resulted in the area meeting the SAE requirements, 2.) not constructed <br />the drainage control features, including use of SoilGuard, as required by the permit, and 3.) <br />developed an incorrect as-built certification map. The DMG NOV abatement date is set for July <br />19. . <br />The disturbance at the shaft 3 area did not reflect what was approved by DMG in the permit. <br />Some areas were not disturbed that initially were planned to be disturbed. The SEDCAD run for <br />the SAE demonstration included a transposed number that allowed the SAE to meet the <br />minimum requirements for settleable solids of 0.5 ml/L. If the correct number had been used, the <br />plan would not have met the minimum requirements. In addition, West Elk did not use the soil <br />stabilization product on disturbed areas called Soil Guard. This was required by the permit as a <br />method to reduce settleable solids to meet the minimum requirements. However, the OSM <br />Hydrologist contacted the manufacturer of this product and learned [hat the product would not <br />have been useful on the disturbed area anyway because of the slopes involved, etc. West Eik had <br />also submitted an incorrect as-built map for DMG's approval prior to the second evaluation trip. <br />The mistakes were not discovered until the May evaluation. West Elk will have to re-evaluate <br />the SAE demonstration and use correct numbers in another SEDCAD run to again demonstrate <br />that this area is even eligible for an SAE. <br />