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ENFORCE23016
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ENFORCE23016
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Entry Properties
Last modified
8/24/2016 7:32:31 PM
Creation date
11/21/2007 10:19:12 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1980007
IBM Index Class Name
Enforcement
Doc Date
5/27/1986
Doc Name
SUBMISSION OF ADDITIONAL INFORMATION RULE 5.04.3(1) FOR NOVS C-86-041 C86-043 AND C-86-043 MT GUNNIS
From
WEST ELK COAL CO INC
To
MLRD
Violation No.
CV1986043
Media Type
D
Archive
No
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Susan Mowry <br />Tom Schreiner <br />Page 5 <br />Several previous discussions with CMLRD inspectors w-re held <br />regarding the driving of dozers by this route. The last discussions with <br />Susan Mowry of CMLRD failed to resolve the issue of whether WECC <br />should amend the permit by a revision or simply reseed the travel <br />route to prevent erosion. WECC with all due respect to the Division, <br />does not feel that we should be .written a notice of violation by one of <br />its inspectors pending an administrative decision as to whether a <br />revision is required or not. <br />There was no evidence of erosion or instability due to the dozer <br />tracks, and no evidence of contamination of the spillway channel. The <br />area was scheduled to be reseeded, raked, and mulched when other <br />spring reclamation work was done. <br />WECC feels very strongly that no environmental damage occurred. <br />One set of dozer tracks had been made down the north facing <br />embankment of FW-1 tramming a dozer to the burrow area located <br />just north and west of FW-1. These dozer tracks did not damage or <br />cause any instability of the pond bank. All drainage and surface runoff <br />from the area is contained by ditches to sediment ponds. The area was <br />scheduled to be reclaimed when other spring reclamation began at the <br />mine site. <br />WECC feels that the dozer tracks are not a violation of permit <br />requirements or standards. All tracks are within the disturbed area of <br />the mine site. WECC also strongly feels that no damage to the <br />environment was caused by these dozer tracks. <br />Attached is a copy of the letter to the Division dated tilay 16, 1986, <br />please use this letter for additional information. <br />Should you have any questions regarding the information provided, <br />please contact me. <br />Sincerely, <br />Dennis Conn <br />Director of Permitting and <br />Environmental Compliance <br />D C /lr <br />cc: T.F. Linn/DAT <br />W.S. Wagener/WECC <br />
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