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iii iiiiiiiiiiiuiii <br />999 <br />interoffice <br />M E M O R A N D U M <br />to: Assessment Officer <br />from: Sandra L. Brown <br />subject: CV-98-006 <br />date: August 5, 1998 <br />CV-98-006 was issued to P&M Coal Company on July 29, 1998 for a violation at the Edna <br />Mine. Date of service is July 31, 1998. The NOV was issued for "Failure to maintain <br />Downdrain #3". It was issued as a result of a Phase I bond release inspection. <br />Downdrain #3 is one of four permanent drainage channels in the reclaimed Moffat Area at the <br />Edna Mine. The other three channels aze rock lined. Downdrain #3 was lined with a <br />geosynthetic erosion control fabric, Landlok ECRM 450. The channel was eroded in several <br />places and the liner was not working effectively. A gully had formed that was up to 33" deep. <br />Designs for the channel said the channel would be triangular, 3:1 sideslopes, 1.13' deep with <br />freeboazd, and 6.78' wide with freeboard. There was some sediment deposition at the outlet end <br />of the drainage, but nothing of great concern. In fact had there been more sediment, the problem <br />may have been noted sooner. The lower part of the channel was in acceptable condition, it was <br />higher up on the hill slope where the channel erosion occurred. As a rough estimate, I would say <br />one-third of the channel was out of compliance. <br />It is not known how long the channel was in this condition. P&M said there were some severe <br />rain storms last fall that may have caused the erosion. However, they do not have on-site <br />precipitation data. The closest data they had was from Steamboat that showed precipitation from <br />September 19-21 approached the 10 yeaz-24 hour storm event of 1.8". A copy of P&M's letter <br />with the data is attached for your information. <br />I looked through old inspection reports and aerial photographs. I found no comments in the <br />inspection reports regazding the condition of Downdrain #3 since the fabric liner was installed in <br />1995. The channel can be seen in old aerial photos, but not to the extent necessary to tell if the <br />channel was eroded. <br />The abatement required P&M to submit a TR, if necessary, for channel redesign within 30 days. <br />P&M submitted a TR on July 31, 1998. It was deemed complete on August 3, 1998. We <br />reviewed it the same day and found the design acceptable. We can issue an approval once the 10 <br />day comment period is over. The second step of the abatement requires the company to <br />reconstruct the drainage within 30 days of approval. <br />Attached is a copy of [he NOV, the inspection report (with the pertinent parts highlighted), a <br />copy of the design in the permit, and some photographs that show the alleged violation. <br />~~. S . I' ~PQ~-c_ Y'e.fl.t.rrl ~Cl ~~ tZJ nom, <br />