ENFORCE25970

• Permit No: C1981012
• IBM Index Class Name: Enforcement
• Doc Date: 4/24/1991
• Doc Name: MLRD RESPONSE TO TDL 91-02-370-003 TV4 NEW ELK MINE C-81-012
• From: OSM
• To: MLRD
• Violation No.: TD1991020370003TV4
• Media Type: D
• Archive: No

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United States Department of the Interior
OFFICE OF SURFACE MINING
RECLAMATION AND ENFORCEMENT
SUITE 310
625 SILVER AVENUE, S.W.
ALBUQUERQUE, NEW MEXICO 87102
April 22, 1991
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In Rcply Refa To:
RtCci'd`
CERTIFIED MAZE - RETURN RECEIPT REQUESTED
P 965 799 371 ppR 2 41991
Mr. Steven G. Renner, Coal Program Supervisor Mined Land
Mined Land Reclamation Division
Department of Natural Resources Reclamation Division
215 Centennial Building
1313 Shezman Street
Denver, CO 80203
Re: MLRD Response to TDL 91-02-370-003 (TV4); New Elk Mine, C-81-012
Dear Mr. Renner:
The Office of Surface Mining Reclamation and Enforcement (OSM),
Albuquerque Field Office (AFO), received the Mined Land Reclamation
Division (MEAD) telefaxed response dated April 1, 1991, to the Ten-Day
Letter (TDL), 91-02-370-003, TV4. Also received was the follow-up
response in the form of a letter dated April 10, 1991, that provided
additional information for review. AFO has reviewed the responses and
has made the following determinations:
1 of 4 - AFO understood the initial MLRD response to be a request
for an additional 10 days to review the permitting procedure and
investigate the record with regard to the underdrain design. The
second MLRD response provided documents from the permit regarding
the underdrain design and an evaluation of this design by Mr. Jim
Pendleton. AFO has reviewed the information submitted and has
determined the response to be inappropriate. The TDL cited MLRD
regulation 4.09.2(2) and stated designs for the subdrainage filter
system are lacking. This regulation requires that a filter system
be designed and constructed using standard geotechnical engineering
methods to ensure the proper function of the rock underdrain
system. The information submitted by MLRD addresses the
configuration of the underdrain, but nowhere in the documents can a
design for the filter system be found. Mr. Pendleton's review of
the permitting procedure and record does not address the filter
system either. Field observations indicate that a filter system is
being used by the operator.