ENFORCE35933

• Permit No: C1980005
• IBM Index Class Name: Enforcement
• Doc Date: 11/7/1985
• Doc Name: Operator Comments
• From: PEABODY COAL CO
• To: MLRD
• Violation No.: CV1985081
• Media Type: D
• Archive: No

Pa-y
PEABODY COAL COMPANY
Nocky Mounuln DNlslon
PJovember 5, 1985
Ms. Anne Baidrige
Geologist/Hydrologist
Minr.3 Land Reclamation Division (MLRG)
423 Ce:,tennial Building
1313 Shermar, StreP,t
Den•.•~r, CO 8u103
Deor Anne:
III IIIIIIIIIIIIIIII
10375 East Harvard Avenue
Suite 400
Denver. Coloratlo 80237
[phone]
~~~~~~ rya .~..`
Gov o ~ ~S YVi/'I
N!{fd~j LAp{{3 t,'i~ ,
Colo. CyAP. at x~,:;,.;a~~ ~~Tip~
The following disc~~ssion serves as Peabody Cool Compa~ry's (PCC) r:-sporlse to tJotice of
Violc,tion (hJOV) C-85-O8/I cs more fully described or: page 3, 5cileciule tr, Notice of
Violation.
In l,~ ref sumr~iary, the NOV states that PCC I•~as failed to ensure that ti:N ec.~i~nent ponds
are maintained Yo allow passage of runoff from 'he 10-year, 24-hu:r _i'~:irn event without
outflow through the emergency spillway, that sediment levels have rn•t ~•;:~n oeriodically
monitored, that sediment hus never been removed from the sedi ~~c~it pc•nds, and that 'ri^e
004 pond dews±rr'i~ig device is presently not functional and may not dewater tF~a pond in a
24-36 hour period. It is also stated that the design for ponds 003 and Ci?~r cn!/ allow for
one year of sediment storage. Four abatement steps and time fram?s were prescriber; in
the NOV to address the above issues.
Abatement step I required PCC to "establish and implement a rieYhod for periodic
monitoring of sediment levels". My letter to you of October 7, 1985 informed CMLRC of
PCC's thorn in-progress sediment survey. My letter also stated that a sediment survey
method, based on the methods used during the current survey, would be developed for
future monitoring activities. It is PCC's understanding that the October 7th letter, al::ng
with the then in-progress sediment surrey, satisfied the requirements for abuic^•,ent step
I of the NOV.
The s~:rveyinc method used to determine sediment levels for ponds 003 uc~d 004 is r'.?-
scribed us follows. Permanently located steel fence posts have been positioned on ei~i!er
side of the ;jam embankment and at one point on the opposite end of the pond fron, 'rhie
dam to create 3 permanent benchmarks for estublisiiirn~ reference grid lines. These
reference grid lines (bused on the permanently located fEri~e pasts) will farm the basis
for future sediment pond monitoring. For both ponds 003 and 004, wr;oden lath were set
at regular intervals along the reference grid lines to establish the grid pattern. The lath
spacing for penrt 003 was 50 feet, while the larger pond 004 had a spacir~ct ;, 75 fee'r.
Using e small boot, the rod men lined up on the grid line; and dropped a sounding line to