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GENERAL53205
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Last modified
8/24/2016 8:38:50 PM
Creation date
11/23/2007 8:25:44 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981013
IBM Index Class Name
General Documents
Doc Date
12/2/1993
Doc Name
RESPONSE TO SHOW CAUSE ORDER & WRITTEN REQUEST FOR REVIEW GOLDEN EAGLE MIN EPN C-81-013
From
BASIN RESOURCES INC
To
DMG
Media Type
D
Archive
No
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Page five <br />Inspection Schedule - Basin is currently conducting regular compliance <br />inspections and will begin the formalized program on January 1, 1994, <br />This will include utilization of the inspection manual described above <br />and at the schedule presented in the plan for various items of <br />compliance. At least monthly inspections will be conducted of all <br />compliance items and others will be inspected weekly or following storm <br />events. <br />Maintenance Items - During inspections, all maintenance items will be <br />listed on work order forms. These work orders will be submitted to the <br />Maintenance Department by the inspector with a schedule and scope of <br />activities to be completed. <br />Inspection Follow-Up - An important aspect of compliance is the follow-up <br />activities which will ensure that all of the necessary items have been <br />completed. It is the responsibility of the inspector to check the items <br />provided to the Maintenance Department to insure the items have been <br />completed with the specified design criteria. If items have not been <br />completed, appropriate actions will be taken to insure maintenance is <br />completed. <br />Third Party Compliance Audits - Basin is in the process of contracting <br />with an outside third party to provide auditing on a regular basis to <br />ensure compliance. These audits will include examination of records to <br />insure that inspections are being conducted on the specified schedule and <br />that all items are in compliance with the approved plan. A close out <br />meeting will be held at the completion of each audit to discuss <br />compliance 'and any issues which will need further attention. <br />Documentation of these audits will be kept in the inspection file. <br />6. COMPLIANCE COMMITMENT <br />Basin has been committed to environmental and regulatory compliance <br />since the acquisition of the mine from Wyoming Fuel Company in May 1991. <br />This commitment is evidenced by the compliance history discussed above, <br />even though the mine has gone through some periods where no coal was <br />produced. <br />Basin's commitment to environmental and regulatory compliance has <br />recently been proven again by the abatement and termination of the <br />subject violations which required extensive time and effort. In hind- <br />sight, Basin should have taken many of these violations to the Board to <br />receive a ruling and possible vacation of those which should not have <br />been written in the form in which they were written. However, Basin did <br />not pursue this course of action with the intent to "work with the <br />Division." <br />It is Basin's intent now that compliance has been achieved to keep <br />it that way. Basin has acquired a 15 year coal contract with Tampa <br />Electric and can not afford to have any environmental or regulatory <br />compliance issues jeopardize the production requirements of the contract. <br />This also is true for the commitment Basin has made to the 180 employees <br />of the mine and to the economy of Las Animas County. <br />
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