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Minutes, September 22-23, 1993 <br />D RAFT 1~. <br />Subject To Soard Appro~ <br />44 <br />area. Staff said that when the snow was removed from the <br />facilities yard area, snow and coal was pushed off of the east <br />side of the pad area (drainage from this area normally drains <br />to the west and ie controlled by a sedimentation pond). Staff <br />said that NOV related the outlet of Culvert E-12 was probably <br />more of a permitting defect, on the parts of the Division and <br />the operator. Staff said that in this case, the operator <br />routed the drainage from the facilities area through the <br />reclaimed area. <br />It was noted that the operator was represented by the same <br />individuals, regarding this matter, as with Item 18. <br />Mr. John Paul, an attorney, said this issue related to a snow <br />management problem at the mine site. He asked Terry Crowner <br />to provide background information, related to the physical <br />site of the mine. <br />Mr. Crowner discussed the elevation of the site, the amount of <br />snowfall and problems with snow removal. He said it is <br />difficult to remove snow from these areas without mixing in <br />some coal, gravel, or mud and pushing it over a berm to some <br />extinct. Mr. Crowner said that at the time of the inspection, <br />the operator had not been able to get equipment up to the site <br />for annual spring cleanup. He said heavy equipment would have <br />caused further damage during that time. <br />Board Member Stewart said she felt the concern about damage <br />from heavy equipment would be applicable to the Grizzly Pad <br />and shop facilities area. However, she asked Mr. Crowner to <br />address the issue of the plugged culvert. <br />Mr. Crowner said that there is a problem with the culvert <br />during the spring. He said the ditches are not cleaned during <br />the winter, due to the snow and ice. Mr. Crowner said the ice <br />and snow in the ditches are allowed to melt which causes a <br />problem with the culvert. He said that his opinion was that <br />the culvert was not plugged during the time of the inspection. <br />In response to an inquiry from the Board, Dave Beverlin <br />referenced the site facilities map and discussed the culvert <br />discharge and the other. areas of the NOV in detail. <br />Mr. Paul said that the NOV stated that coal was being <br />deposited on undisturbed areas in all three instances. He <br />said that the operator's opinion was that this was not correct <br />in each of the three instances. Mr. Paul said that the <br />operator was within disturbed area boundaries in each case. <br />He said the Culvert E-12 is a road ditch which leads to <br />