ENFORCE36565

• Permit No: C1982057
• IBM Index Class Name: Enforcement
• Doc Date: 7/25/1995
• Doc Name: EXTENSION OF ABATEMENT DEADLINE BEYOND 90 DAYS NOV C-95-006 & NOV C-95-007 SENECA COAL CO SENECA II
• From: DMG
• To: MIKE LONG
• Violation No.: CV1995007
• Media Type: D
• Archive: No

STATE OF COLOIZ~DO
DIVISION OF MINERALS AND GEOLOGY
Department of Nawral Resources
1313 Sherman 51., Room 275 I+~
Denver, Colorado A(R03 I
Phone: [phone]
FAX: (303183?-R106
DEPARTMENT OF
NATURAL
DATE: June 29, 1995 RESOURCES
Roy Romer
TO: Mike Long, Director cOVe`°°'
tames 5. Lnchhead
Ereculiee DueUOr
FROM: Wally Erickson ~ M;°hae, s. Lnng
Dmmm~ D~reuor
RE: Extension of Abatement Deadline Beyond 90 Days,
NOV C-95-006 and NOV C-95-007,
Seneca Coal Company, Seneca II W, Permit No. C-82-057.
Please find attached, Seneca Coal Company's request to extend the abatement deadline
beyond 90 days for NOV C-95-006 and NOV C-95-007. The subject violations were
issued 3/31/95. The 90 day period closes 6/29/95. Abatement requirements for both
violations included submittal of a TR and field implementation of the designs approved
in the TR following final approval by DMG. Seneca's request states that this extension
is necessary to allow time for DMG to complete its review process of the TR and for
Seneca to implement the plans, following final approval by DMG.
As the lead specialist for this mine, I can verify that inclement whether has persisted at
the mine site throughout March, April, May and the first half of June. Muddy field
conditions have hindered completion of interim remedial abatement steps. DMG .
received the initial submittal of TR-22 on 6/9/95. Additional material was submitted on
6/15/95. TR-22 was found complete un 6719/95. DMG is currently reviewing TR-22.
Rule 5.03.2(2)(c) lists the five circumstances which may qualify a surface coal mine for
extension of the abatement deadline beyond 90 days. Climatic conditions and approval
of TR after the 90 day period closes are listed as qualifying circumstances. I recommend
approval of the abatement deadline to 7/29/95.
Rule 5.03.2(2)(c) lists five circumstances which may justify extending NOV abatement
deadlines beyond 90 days. Climatic conditions and ongoing review of permitting
submitted as abatement of NOV's C-95-006 and 007 have made abatement within 90
days unreasonable. I recommend that you extend the abatement deadline to July 29,
1995