1988-06-20_GENERAL DOCUMENTS - C1981017

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Mr. Robert Hagen - 2 - May 27, 1988 This backup was not due to improper grading on the bench area or the fact that it faces uphill . Under proper maintenance conditions, this situation would not have occurred. The road ditch is sufficient to contain any rim-off from the road in a normal situation. It should also be restated that the Division does not believe that snow pushing over the upper bench constitutes drainage being directed over the outslope of a pile. The purpose of the snow pushing is to preclude the snow from melting on the upper surface of the pile and draining down over the first outslope and bench. By pushing the snow over the outslope, the distance the melt water travels is greatly reduced. The effectiveness of and efficiency of this method of handling the snow removal has been further discussed during the OSM oversight inspections of refuse piles. To summarize, the Division finds that no violation exists at the Sutev Refuse Pile due to the Division' s previous approval of the practice of pushing snow over the front face onto the bench area. The Division also has found no evidence that the practice is not effective in removing snow drainage from the area. Furthermore, due to the fact of the Division' s approval , the Division believes that this issue is a special study oversight issue and should be handled within the realm of OSM's current oversight of refuse piles. Your position on this issue appears inconsistent with Directive No. 27, and we ask that you reconsider in light of the information and clarification we have provided. If you have any Questions concernino this matter, please call . We would appreciate your written response to the issues raised in this letter. Thank you for your consideration. Sincerely, Robert G. Liddle Senior Reclamation Specialist RGL/hm cc: Candy Thompson 7 519F