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ENFORCE22001
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Last modified
8/24/2016 7:31:51 PM
Creation date
11/21/2007 10:04:53 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1982056
IBM Index Class Name
Enforcement
Doc Date
6/6/2005
Doc Name
Operator Comment Letter
From
Twentymile Coal Company
To
DMG
Violation No.
CV2005005
Media Type
D
Archive
No
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The circumstances resulting in the observed topsoil storage concerns were determined as soon as <br />reasonably possible after the inspection and described in an a-mail (dated 5/05/05, copy attached <br />for reference) from Jerry Nettleton, of TOC, to Byron Walker, of the Colorado Division of <br />Minerals and Geology (CDMG). The thin layer of road-base material observed on the windrowed <br />topsoil resulted from melting of snow that had been plowed off the access road during the winter. <br />During plowing operations, minor amounts of road-base material had been picked-up and mixed <br />with the snow, appearing as a thin surface deposit on the windrowed topsoil material, with <br />snowmeh in the spring. It should be noted that the volume of road-base material on the <br />windrowed topsoil is negligible, in most cases not even completely covering the topsoil. <br />TCC is careful to review and evaluate all materials used and consumed at the Mme for potential <br />environmental impacts and compatibility with nattual materials. TCC collected a sample of the <br />stockpiled road-base material used on the 18-Right Ventilation Shaft access road and had it <br />analyzed for soil suitability parameters. The analysis results (copy attached for reference) confirm <br />that the road-base material meets applicable soil suitability criteria, and does not represent a <br />potential contaminant that would adversely impact suitability of topsoil as a vegetative growth <br />medium <br />As noted under Items 1 through 4 above, TCC took reasonable steps to recover, place, and protect <br />available topsoil resources prior to construction of the 18-Right Ventilation Shaft access road. In <br />practice, adverse weather conditions during these operations affected the contractor's ability to <br />perform and complete the work in the best manner possible, and work was ongoing at the time of <br />the inspection to complete grading of the topsoil windrows to a stable configuration in preparation <br />for seeding to stabilize the topsoil and protect it from erosion. <br />Indications of possible mixing of cut material and topsoil occurred in those areas where there was <br />either excess cut material or where rocky material had to be ripped for road construction. In areas <br />where excess cut was required, topsoil was normally stripped and placed in stockpile prior to road <br />construction to provide adequate room for temporary stockpiling of the excess cut material. In <br />most cases, surficial soils in the rocky areas were limited, poorly developed, and contained a <br />significant percentage of rocky fragments, so it was impractical to separate the soil, and both the <br />poor soil and cut materials were graded to the side of the road for future use in filling and <br />reclaiming the cut areas (rocky materials were not rued in road construction due to concerns about <br />adequate compaction). Any limited amounts of suitable topsoil in the rocky areas were, however, <br />salvaged prior to road construction. Because the rocky areas were typically the steeper areas, any <br />salvaged topsoil from these areas was placed in the main (pad area) topsoil pile. <br />6) After reviewing field conditions, TCC concurs with the CDMG that placement of topsoil materials <br />in stockpiles will provide for better topsoil protection than the cttrrent windrowed configuration <br />(as indicated by abatement (2)(b)), has field identified practical topsoil stockpile locations, and is <br />ctttrentiy preparing a Technical Revision application reflecting recovery of windrowed topsoil and <br />placement in stockpile. <br />NOV CV-2005-005 3 6/3/2005 <br />
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