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<br />required P6M to prevent the continued accumulation. During late fall <br />(1980) and spring (1981) all of the metal splices along the belt were <br />replaced with vulcanized splices to eliminate the coal fines that were <br />passing between the links of the metal splices. Additionally, brushes and <br />scrapers were added at the transfers buildings to clean the belts and <br />collect in a controlled manner any residual coal fines which may have <br />adhered to the belts. Some coal dust still falls off the belt where the <br />belt comes into contact with the return idlers as the inverted empty belt <br />travels back up the hill side. <br />It was mutually agreed between MLRD technical staff and P&M during a <br />meeting at the mine on February 2, 1982 that it was not possible to <br />completely eliminate the loss of coal tines and the efforts mentioned above <br />constituted best control technology currently available. Additionally, it <br />was agreed that no violation of the performance standards was occurring <br />because all drainage from the conveyor system was treated by the tipple <br />area sediment ponds. Therefore, no damage to fish, wildlife, and related <br />• environmental values was occurring, nor were additional contributions of <br />suspended solids being added to streamflow or runoff outside the permit <br />area. <br />As previously stated, the vegetation and topsoil beneath and adjacent <br />to the conveyor belt were left in place due to the steepness of slopes, <br />safety concerns and a lack of regulations requiring salvage of topsoil <br />(prior to the passage of SMCRA). With the passage of SMCRA and the <br />subsequent permanent program regulations, innovative approaches have been <br />implemented to bring the facility into conformance with the regulations. <br />SMCRA permits non-salvaging of topsoil in areas for good cause shown. In <br />this instance, as approved in the initial permit submittal, it was not <br />possible to salvage the topsoil under or adjacent to the conveyor belt <br />because of safety concerns about equipment and operators on the steep <br />slopes. Therefore, to comply with the regulations to control and minimize <br />diminution or degradation of water quality and quantity, control and <br />minimize erosion and siltation, and prevent damage to public or private <br />property a three-fold compliance approach was taken. <br />First, all drainage from the conveyor system was directed toward the <br />• tipple sediment ponds for treatment prior to being released from the permit <br />Mid-term '94 3.6-6 September 15, 1994 <br />