1983-11-22_ENFORCEMENT - C1981017

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STATE OF COLORADO RICHARD D. L.�MM, r;ovornor DEPARTMENT OF NATURAL RESOURCES D. Monte Pascoe,Executive Director MINED LAND RECLAMATION 423 Centennial Building,1313 Sherman Street j Denver, Colorado 80203 Tel. (303) 866-3567 David C. Shelton Director July 8, 1982 Mr. Doug Bowman Mid-Continent Resources, Inc. P.O. Box 158 Carbondale, Colorado 81623 Re: Assessment Conference for Notices of Violation 82-26 and 82-28 Attached Settlement Agreement Our File No. C-017-81; Coal Basin Mines Dear Mr. Bowman: After considering the information and evidence presented in the Assessment Conference held on June 29, 1982, I want to present to you what I perceive as the central issue and propose a settlement agreement. The issue centered upon identifying acceptable methods of snow removal. Given the location of the Mid-Continent mines, snow removal is a major oper- ational problem. It is difficult to predict the amount of snowfall and difficult to dispose of considering the limited space. Acceptable practice in the past has been to push snow on the outslope of benches and roads and into drainages. The disposal of snow in this manner has not, until now, caused significant problems. In light of the Notices of Violation and in an effort to prevent future environmental problems, snow removal practices at Mid-Continent need to be reexamined. Part of the examination needs to assess what is acceptable snow removal practice as it pertains to the disposal of snow mixed with coal fines outside of berms and into drainage areas. However, it must be emphasized that pushing snow that contains oil and grease, debris and other deleterious material beyond buffer zones and into drainages is not an acceptable practice. Another part of the examination needs to consider the identification of areas that are particularly susceptible to environmental problems caused by snow removal practices. Specific snow removal plans should be drafted for those areas.