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iiiiii iiiiii iiii iii <br />999 <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department o(Natural Resources <br />1313 Sherman St., Room 21.i <br />Denver, CO 80203 <br />Phone:(3031866-1567 <br />FAX: 13031 832-8106 <br />October 7, 1993 <br />Attn: Assessment Officer <br />TO: File ~// ~ <br />FM: Shawn Smith~~y/~ <br />Re: NOV C-93-131. Recommendation: Issues to Consider <br />Southfield Mine (C-81-014) <br />Dear Assessment Officer: <br />OF.ep(O <br />~~~=4b <br />:rte'. ~-~`;.o <br />Ray Romer <br />Govemur <br />Michael 8. Long, <br />Division Duecto~ <br />NOV C-93-131 was issued for failure to design, construct and <br />certify temporary impoundments (SAE sedimentation traps and sumps) <br />per the regulations, in particular Rule 4.05.9(2), 4.05.6(2), <br />4.05.6(3)(d), 4.05.6(3)(e), 4.05.6(5), 4.05.6(6) and 4.05.6(8-12). <br />Seriousness: There are five areas that are addressed in this NOV; <br />the west and east loadout area where there are three SAES, the <br />south mine fan sump area SAE and the rock dust storage SAE. This <br />violation is the result of re-interpretation of the regulations by <br />the OSM, and has been the subject of inter-agency debate this year. <br />Since the areas in question have now been renamed temporary <br />impoundments, new design criteria have taken effect. All areas <br />showed that no surface flow ever was discharged from the SAErs. <br />Damage to the local environment is non-existent, this being an <br />administrative interpretation of the regulations and their intent. <br />I recommend that the seriousness be low. <br />Fault: In this particular case, the operator had just recently <br />submitted 10 year 24 hour event calculations under the required SAE <br />demonstrations through a Mid-term review Technical Revision. The <br />debate on this issue is one between the OSM and the Division, with <br />the operator caught in a re-interpretation of the SAE issues <br />regarding 25 year 24 hour event requirements as under the temporary <br />impoundment regulations. <br />I recommend no fault on the operator's behalf, due to the new <br />interpretation of the regulations. <br />Good Faith: There has been no extraordinary effort to abate this <br />violation at this time by the operator. <br />