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ENFORCE31101
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ENFORCE31101
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Last modified
8/24/2016 7:42:53 PM
Creation date
11/21/2007 12:52:26 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981019
IBM Index Class Name
Enforcement
Doc Date
8/17/1993
Doc Name
NOV C-93-072 PN C-81-019 COLOWYO COAL CO COLOWYO RESPONSE TO 07-08-93 CIVIL PENALTY ASSESSMENTS
From
COLOWYO COAL CO
To
DMG
Violation No.
CV1993072
Media Type
D
Archive
No
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<br />The Division also appears to have some misconception <br />regarding the final construction of dozer cuts. The attached <br />pictures show the final configuration of the dozer cuts on the <br />stockpiles. Any topsoil pushed below the stockpile is blended back <br />into the toe of the downslope side of the stockpile and seeded with <br />the rest of the stockpile. In its final configuration, the topsoil <br />is not simply left haphazardly below the stockpiles. <br />"Seriousness" <br />These topsoil stockpiles in question represent <br />approximately 40,000 bcy of topsoil. During 1993 it was estimated <br />that 425,000 bcy would be removed by contractors in Section 16. <br />Our records show that 435,000 bcy were removed and stockpiled, or <br />10,000 bcy over the estimate! The Division's assertion that "a <br />considerable amount of topsoil was lost" is simply not true. The <br />downslope topsoil was not "lost" rather it was blended back into <br />the stockpiles during the later repair work. Erosional loss of <br />topsoil when compared to the large volume stripped in Section 16 is <br />insignificant. <br />For comparison consider the following analysis. If <br />theoretically, 99$ of topsoil is recovered in Section 16 (which is <br />probably unrealistic), 1$ (4,350 bcy) of topsoil would then be left <br />in place and never recovered. The volume of any topsoil "lost" <br />from the dozer cuts was much less than expected losses of topsoil <br />from the normal stripping operation. <br />"Fault" <br />Topsoil stripping at Colowyo is not taken lightly. <br />Considerable effort is employed to strip hundreds of thousands of <br />yards, regrade stockpiles, seed stockpiles and provide for <br />drainage. The Division's concerns are routinely addressed during <br />all topsoil operations. The Division's allegation that in this <br />particular instance Colowyo failed to address specific concerns is <br />a misrepresentation of the facts. Colowyo employed great resources <br />to the topsoil stripping operation in Section 16 and failure to <br />complete the water cutouts well before fall weather set in does not <br />represent a high degree of negligence. The major reason for delay <br />in topsoil completion was due to the delay in approval of PR-O1. <br />Good Faith <br />The Division did not "order" Colowyo to construct the <br />diversion ditch, rather we were to "protect topsoil from erosion <br />from water" (NOV C-93-072). It was Colowyo's decision to build the <br />ditch in order to divert rainfall and snowmelt away from the area <br />so that repair work could commence. <br />
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