REV92050

• Permit No: C1981041
• IBM Index Class Name: Revision
• Doc Date: 12/19/1997
• Doc Name: ROADSIDE ISSUES ETC
• Type & Sequence: RN3
• Media Type: D
• Archive: No

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lpr
MathewsD~COAL~DNRML
Roadside issues, etc.
Friday, December 19, 1997 9:49:06 MST
N
Normal
Sounds like you're making headway with the veg rules. Dealing with Larry
Reschke on a frequent basis makes me long for the good old days of writing
rules and doing meetings with Forrest, Jim, and the boys.
A rather contentious issue came up at my Roadside inspection yesterday.
First some background. A couple weeks ago, as you know, I checked final
abatement of NOV 97-001 (Pond 12) and terminated the NOV. Reschke was not on
site that afternoon, and I ended up looking at the pond with a guy named Bob
Blue. I think he is an underground mine foreman, but he had been involved in
the pond construction effort, and apparently was Reschke's designee to
accompany me. The pond was constructed, embankments and spillways were in
apparent compliance, and the pond was holding minewater. There were a couple
aspects of the plan which had not been completed, but in my judgement they
were fairly minor, and did not warrant issuance of an FTA-CO. These items
were:
1) The approved pond design drawing (RSN-47) showed the mine discharge line
to be buried, and entering the pond at the northeast corner, approximately
115 feet from the primary spillway. At the time of my inspection, the water
line was on the surface, and entered the pond at the southeast corner. Bob
Blue indicated that this was temporary and they intended to bury the line in
compliance with the plan.
2) The ditch shown on RSN-47 along the north side of Pond 12 which directs
a small area of disturbed drainage to Pond 5 had not yet been completed.
I indicated to Mr. Blue that these items needed to be completed and requested
that they be done within the next week.
When I inspected the site on the afternoon of December 18, Larry Reschke
complained stridently that I had been way out of line in directing them to
bury the water line, as he said that whether the line was buried or not, and
where it entered the pond was not a component of the pond design, and was not
within my authority. Upon arriving at the pond site, I was surprised to see
that the water line had been buried along the Pond 5 embankment, and entered
Pond 12 at the southeast corner, approximately 25 feet or so from the
spillway, rather than at the northeast corner, as depicted on the plan.
Reschke says he has no intent to relocate the line, that the inlet location
has no bearing on the functioning of the pond, and that he will protest any
directive from us to relocate the inlet. The ditch had been completed in
accordance with the design.
Before I make my next move, I seek your wise counsel. I have FAXED to you a
copy of the RSN-47 design drawing. The technical concern I have is whether
the inlet pipe location adjacent to the spillway would result in short
circuiting. Reschke says that is not a consideration for this pond because
settling alone is insufficient, and if high tss water does enter the pond,
flocculant treatment would be necessary. I said I would consult with our
hydrologists on this issue. Could you run this by Erica, Berry, or other
hydrologists and let me know what they think? If the inlet location is of
consequence from a technical standpoint, we need to decide how to proceed, in
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