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In conclusion, TC questions the basis for the NOV and whether it should have been issued to TC, as <br />further detailed by the following comments: <br />Failure to place all underground development waste in existing disposal areas approved by the <br />Division within the Permit Area — Most underground development material either remains <br />underground in abandoned mine areas, or if it is rocky material, is shipped out of the mine on the <br />conveyor belt and routed directly to the CRDA. Only materials which cannot be placed in the <br />CRDA due to "combustibility" concerns are shipped off -site to a State approved disposal facility. <br />Diversion of any waste materials to any location other than a State approved disposal facility was <br />done without TC's knowledge or authorization. <br />Failure to dispose of non-coal wastes in a State approved disposal site operated in accordance <br />with local. State, and Federal requirements — TC's policy and practice is to contract for transport <br />and disposal of all non -coal wastes in a State approved disposal facility (Twin Landfill). <br />Diversion of any waste materials to any location other than a State approved disposal facility was <br />done without TC's knowledge or authorization. (MUCH OF THE WASTE EXPORTED WAS <br />Failure to conduct all surface coal mining and reclamation operations only as described in the <br />approved application. Failure to comply with the terms and conditions of the permit, all <br />applicable performance standards of the Act, and the requirements of the Rules. — To the best of <br />our knowledge and ability, TC has, and continues to, conduct all mining and related activities <br />according to our approved Permit and in full compliance with all applicable laws, rules, and <br />regulations. <br />TC is committed to full compliance with all applicable regulatory requirements. Although we question <br />the basis for the NOV, and whether it should have been issued to TC, we remain committed to working <br />with the CDRMS to resolve all outstanding issues in a timely and responsible manner. Consistent with <br />that commitment, we have developed, submitted, and will proceed immediately on receipt of CDRMS <br />approval, with the following Abatement Plan. <br />Abatement Plan <br />The NOV specifies 3 steps as necessary to abate the NOV. This Abatement Plan specifically addresses <br />Abatement Step 1: <br />Submit a plan to ensure that; a) the underground development waste subject to this NOV is <br />segregated from non -coal waste, and disposed of in the approved Refuse Disposal Area; and b) <br />the non -coal waste subject to this NOV is disposed of in a State approved disposal site operating <br />in accordance with local, State, and Federal requirements. <br />In order to abate the NOV, TC proposes to complete the following: <br />1) Survey the existing piles of imported material at both the Ross and Deakins Pits to determine how <br />much material is present (this survey has already been conducted) <br />2) Work with our contractor to load and transport the existing pile of imported material from the <br />Deakins Pit to the Ross Pit, where it will be combined with an existing pile of similar material for <br />further processing <br />3) Work with our contractor to process the imported material currently stockpiled at the Ross Pit <br />(plus the additional material transferred from the Deakins Pit) to generate four separate product <br />