Laserfiche WebLink
_p_ <br />Initially, let me note two technical errors 1n the above quotation. <br />1. The OSM inspector cites the portion of the Colorado regulations <br />dealing with discharge structures from sedimentation ponds, permanent and <br />temporary Impoundments, coal processing waste dams and embankments, and <br />diversion. The violation is written to address road drainage <br />structures. The applicable portions of the Colorado statute and <br />regulations were cited at the beginning of this memorandum. <br />2. As noted to 1. above, in this Instance the area of concern is <br />road drainage structures, not diversions. <br />In two separate inspections, on June 7, 1983 and July 7, 1983, I observed <br />the culverts cited in the OSM violation. The operator had n.ot altered <br />the structure or functioning of the road drainage system, though they <br />were aware that OSM had a concern regarding the workings of the system. <br />The operator has five culverts along the haul road from the valley <br />opening of Munger Canyon to the bench area. These culverts convey road <br />drainage from the Inside edge of the road through culverts underneath the <br />road to drain Into the ephemeral Hunger Creek. The operator has <br />constructed wooden drop boxes at the Inlet of each culvert, which serve <br />as energy dissipators and sediment traps. Additionally, in the road <br />drainage ditch Immediately above the drop box, the operator leas staked <br />straw bales as a further method of slowing and filtering road drainage. <br />The culverts under the road are of a corrugated metal pipe type and <br />emerge on the outslope of the road. At the outfall of each of the <br />culverts, the operator has cut the last 2-4 feet of the end of the <br />culvert and bent it downward to reduce the outfall distance. <br />Additionally, the operator has placed rubber conveyor belt beneath the <br />end of the culvert outflow to reduce outfall erosion. Around the <br />perimeter of the outfall, the operator has placed cobbles and gravel. <br />Cobbles and rock have been selectively placed below the culvert outfalls. <br />Observations of the drainage pathways below the culverts did not indicate <br />an erosion problem to me on either of my inspections for any of the <br />culverts. I observed and Inspected natural drainages above the haul road <br />to compare appearance and attributes and could discern no siynificant <br />difference between natural drainageways above the haul road and drainaye <br />paths below culvert outfalls. <br />From my observations and from my reading of the Colorado statute and <br />regulations, the operator was and is not in violation for the followiny <br />reasons: <br />