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r ~c~~~N <br />PEABOpY COAL COMPANY <br />RoekY Meunldn pWl~lon <br />• <br />f lovember 5, 1985 <br />Ms. Anne Baldrige <br />Geologist/Hydrologist <br />Mined Lond Reclamation Division (MLRD) <br />423 Centennial Building <br />1313 Sherman Street <br />Denver, CO 80203 <br />Dear Anne: <br />10775 Eeel Herverd Avenue <br />Sulla e00 <br />Denver, Colorado 80271 <br />(707) 777.5907 <br />Tl,e following discussion serves as Peabody Coal Company's (PCC) response to Notice of <br />Violation (NOV) C-85-0891 as more fully described on page 3, Schedule 1o Notice of <br />Violation. <br />In brief summary, the NOV states that PCC has failed to ensure Ihoi the sediment ponds <br />are maintained to allow passage of runoff from the 10-year, 24-hour storm event without <br />outflow Ihrovgh the emergency spillway, that sediment levels have not been periodically <br />.monitored, that sediment has never been removed from the sediment ponds, and that the <br />004 pond dewatering device Is presently not lunctlonol and may not dewoter the pond in a <br />24-36 hour period. It is also slated chat the design for ponds 003 and 004 only allow for <br />one year of sediment storage. Four abatement steps and time frames were prescribed in <br />the NOV to address the above Issues. <br />Abatement step I required PCC io "establish and Implement a method for periodic <br />monitoring of sediment levels". My letter to you of October 7, 1985 informed CMLRD of <br />PCC's Il,en in-progress sediment survey. My letter also stated that a sediment survey <br />method, based on tl,e methods used during the current survey, would be developed for <br />future monitoring activities. It is PCCs understanding that the October 7th letter, along <br />with the Then In-progress sediment survey, satisfied the requirements for abatement step <br />I of the NOV: <br />The surveying method used io determine sediment levels for ponds 003 and 004 is de- <br />scribed as follows. Permanently located steel fence posts have been positioned on either <br />side of the dam embankment and at one point on tl,e opposite end of the pond from the <br />dam io create 3 permanent benchmarks for establishing reference grid lines. These <br />reference grid Tines (based on the permanently located fence posts) will form the basis <br />for future sediment pond monitoring. For both ponds 003 and 004, wooden lath were set <br />at regular intervals along the reference grid lines to establish the grid pattern. The lath <br />spacing for pond 003 was 50 feet, while the larger pond 004 had a spacinq of 75 feet. <br />sing a small boat, the rod men lined up on the grid Ilnes and dropped a sovnding line to <br />