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Ms. Ann Tatum -2- December 12, 1994 <br />In your letter of November 29, you had asked, "does the problem for spontaneous combustion <br />increase if the stockpiles are allowed to increase in size beyond the approved permit allowance?" <br />First, it should be noted that the size of coal stockpiles is not a specific regulatory criterion; as <br />such, the Division does not regulate the size of piles. We do regulate the area that the coal <br />stockpile rests upon. <br />When a coal stockpile area is designated in an application submitted by the operator, the Division <br />ensures that a drainage system is designed to effectively handle the surfa~vater runoff from that <br />stockpile and direct it to a sedimentation pond. The Division further ensures that an appropriate <br />reclamation plan for the stockpile area is provided in the application. As a permittee's need for <br />increased storage area arises, the Division reviews the requisite revision applications to ensure <br />that the existing surface drainage systems and reclamation plans are correctly modified. <br />Second, according to Dr. Pendleton, the potential for spontaneous combustion of a coal stockpile <br />may increase with an increase in the size of the stockpile if there is no corresponding increase in <br />management of the stockpile by the permittee to maintain oxygen availability to a minimum. <br />Examples of pile management would include compaction and sealing of the pile to minimize void <br />space in the pile, which Basin Resources is currently employing. <br />Other questions raised in your November 29, 1994 letter pertained to whether the Division has <br />obtained test analysis of the coal being mined at the Golden Eagle Mine, and whether the State <br />requires periodic testing of coal. As mentioned earlier, the permit application documents contain <br />an analysis of the coal typically mined at the Golden Eagle (copy of analysis is provided). <br />Current State law and regulations do not direct the State to require periodic testing of coal for the <br />purposes of monitoring the potential for spontaneous combustion. <br />We have provided copies of the following NOVs issued to Basin Resources since 1990 pertaining <br />to stockpiling of coal, coal pollution, coal dust pollution, etc.: C-93-039, C-93-063, C-93-122, <br />C-93-126, and C-94-008. <br />We have also provided a copy of Basin's November 1, 1993 letter to the Division regarding their <br />measures taken to minimize the potential for spontaneous combustion of their coal stockpiles. <br />Your copying costs are $4.75. To date your total copying costs are $94.50. We have not yet <br />received your payment of any of these costs. <br />Please call for any further assistance we may provide. <br />Sincerely, <br />~b?r~ <br />Daniel I. Hernande/ z~~^ <br />Senior Environmental Protection Specialist <br />D1FI/bjw <br />Enclosure(s) <br />M:\OSS\8I W\Dm.GE <br />