1988-06-20_GENERAL DOCUMENTS - C1981017

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Mike Long - 3 - May 18, 1988 Lou Hamm observed at the conclusion of our lengthy discussion that he is prone to concur with my opinions regarding snow removal . Apparently, Gary Fritz has rejected our 10-day notice response to this issue as "inappropriate" and intends to issue a Federal violation to Mid-Continent Resources for pushing snow over the crest of the pile. Lou continues to believe that wider benches would help stabilize the pile and offset this problem. I observed that it could also decrease storage capacity within the sutey waste pile, which is a very critical consideration at the Coal Basin mine. Bernie Freeman also volunteered an observation which was interesting. Based on experience in New Mexico, Bernie suggested that he believes it inefficient to completely topsoil terrace benches. They (OSMRE) have observed that cross flow through the groin at the back of the terrace commonly erodes the topsoil placed within the groin. The OSMRE believes it desirable to leave the groin area untopsoiled. Natural sediment will eventually infill the groin, if flow velocities permit, and that area will develop mature cover in time. Bernie cautioned that such a design detail would have to be properly described within the permitting document. At the conclusion of our visit to the Coal Basin waste pile, Bob and I continued the discussion with Bernie and Lou. While Lou stated that he was satisfied with situations at the Coal Basin waste pile, Bernie seemed less convinced. Our exchange at the Powderhorn pile was considerably less satisfying. Lou Hamm apparently authored a memo last winter expressing concern about seeps issuing from the face of the Roadside/Cameo Pile No. 1 . Seepage does issue along three or four distinct horizons spaced on about 30 to 20 foot intervals vertically on the face of the pile. The lowest horizon displays active seepage while the upper horizons are evidenced by salt deposits from elevated evaporation of seepage. The lower two terraces at the Powderhorn pile were not graded to cross drain and do appear to pond water in several locations. A 10-day notice was issued by Gary Fritz for this concern in mid-1987. The Division responded by issuing a Notice of Violation to Powderhorn Coal citing the failure to properly grade the top of the waste pile to drain to the peripheral ditches and the failure to properly grade the lower benches. This NOV was the subject of an assessment conference, conducted by Sandy Brown. Jim Stover, then environmental representative for Powderhorn Coal , referenced the original permit documents vagery regarding which direction the lower benches were to drain. He also presented testimony from Ken Meyers, the original consulting engineer for the waste pile, stating that it didn't make any difference to Mr. Meyers which direction the benches drained as long as water was not retained on the pile. Based on this information, Sandy Brown recommended an amendment to the NOV's abatement requirements. Powderhorn was required to regrade the top surface and uppermost (third) terrace bench, in order to prevent drainage from the top of the pile breakinq over onto the pile face. The two lower benches were not required to be regraded in the operational situation, but were only required to drain. When the Roadside/Cameo permit was renewed last fall , Jim Stover inserted this wording into the renewal document, citing the findings of the NOV process as justification.