ENFORCE23949 - Laserfiche WebLink

Home Browse Search

PCC 11 /92 page 3 the runoff to be directed away from the face, at a 2 - 5% grade, to the perimeter ditches. The terrace in this location is designed to direct runoff to a perimeter ditch on the southern edge of the pile. Drainage to the face is specifically not allowed. PCC acknowledged that the terrace was not installed properly and will be regraded. This terrace has existed like this since 1989. 3) There were not any certifications done during the critical stages of construction. It was unclear whether or not photographs of the underdrain construction were required under the Colorado program during these stages, but certifications were required. This is particularly worrisome since the only underdrain outlet that could be observed was for #3. Abatement of this violation should result in the outlets of underdrains #1 and 2/2A being exposed both before and after deposition of the topsoil and non- toxic, non-combustible material. 4) OSM has long held the position that reclamation of refuse piles is to be accomplished concurrently with refuse pile construction. Reclamation of a refuse pile does not occur after the construction lifetime of a pile, but will be done as the pile is being constructed. DMG has held that the starting date for reclamation of any part of the mine as beginning upon permanent cessation of all operations at the entire mine complex (See HO response to TDN 91-02-352-001 appeal and reclamation Atari). 'The permit shows- - -- ~ --- that in December 10 1986, there were total clean reserves of 36,483,000 tons and a maximum production of 1,100,000 tons. Following DMG logic, this means that reclamation of the piles would not have to start until the year 2020. This is not contemporaneous reclamation. The site currently is producing less than 200,000 tons per year and waste has not been added to CRDA #1 in years. So, the date that coal reserves will be depleted will be extended. The pile must be concurrently reclaimed with construction activities. While the subject of DMG NOV C-92-38 is not a part of this TDN, the conditions are a result of delayed reclamation. PCC should have constructed the ditch as per the specifications up to the level of the third terrace. This means that the ditch would have been lined with riprap by now. CRDA #2 -The problems with this pile are not as numerous as with CRDA #1 because the pile is not as old and not as big. The types of problems observed though are the same as for CRDA #1. 1) DMG issued an NOV to address the eroded ditch on CRDA #1 but not the East collection ditch on CRDA #2. Therefore, the East collection ditch is included in this TDN. The ditch should be completed and lined with riprap as per design up to the level of the second terrace. Field conditions are such that the riprap has not been placed and erosion has occurred in the ditch to the point where a violation exists. 2) As in the discussion for CRDA #1 above, this fill has not had the certifications done during the critical stages. This pile does not have underdrains though. 3) Also as discussed above for CRDA #2, this pile is delinquent in reclamation. Reclamation should have been accomplished from the level of second terrace to the toe by this time.