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i <br />All <br />TRI -STATE GENERATION AND TRANSMISSION ASSOCIATION, INC. <br />HEADQUARTERS: P.O. BOX 33695 DENVER, COLORADO 80233 -0695 303 - 452 -6111 <br />July 15, 2014 <br />Mr. Michael P. Boulay <br />Environmental Protection Specialist <br />101 S. 3rd Street, Suite 301 <br />Grand Junction, CO 81501 <br />RE: New Horizon North Mine (C- 2010 -089), Response to Notice of Violation RECEIVED <br />CV- 2014 -004 and Assessment Conference Request <br />JUL 15 2 @14 <br />Dear Mr. Boulay: Division of Reclamation, <br />Mining & Safety <br />Tri -State Generation and Transmission Association, Inc. (Tri- State) is the parent company of <br />Western Fuels- Colorado, a Limited Liability Company (Western Fuels- Colorado). The New Horizon <br />North Mine operates under Colorado Division of Reclamation, Mining and Safety (Division) Permit No. <br />C- 2010 -089. Tri -State on behalf of Western Fuels- Colorado is submitting this additional information for <br />the above referenced NOV to assist the Division with the facts surrounding the violation, and to assist in <br />mitigating any civil penalties that may be assessed. <br />The Division, with the Office of Surface Mining (OSM), conducted a complete inspection of the <br />New Horizon North Mine on June 3, 2014. The inspection report, dated June 26, 2014, noted that there <br />were discrepancies from the as -built information for the NHN -001 East and West Ditches. NOV 2014- <br />004 was issued to Western Fuels - Colorado on June 30, 2014, and stated that significant differences were <br />identified between as -built documentation compared to site observations made during the inspection. <br />Permit History <br />During construction of the NHN -001 East and West Ditches, it was determined that the approved <br />ditch designs needed to be altered to effectively conform to actual site conditions, as well as limit the <br />overall footprint of the ditches to facilitate additional room for mining activities. It was determined that a <br />triangular ditch with a smaller cross - sectional area could be constructed that would assist in limiting the <br />overall footprint of both ditches. SEDCAD modeling indicated that a triangular ditch was sufficient to <br />convey all flows through the ditches to Pond 001. <br />Once ditch construction was completed in 2013, as -built documentation was submitted to the <br />Division through Technical Revision 04 (TR -04). While submission of as -built information for ditch <br />construction is not required under the Colorado Surface Coal Mining and Reclamation Act, it was deemed <br />necessary to provide the Division with an accurate depiction of the as -built condition since it varied from <br />the approved designs included in Appendix 2.05.3(4) -1. The September 91h Adequacy Review from the <br />Division under comment #5 asked whether the dimension shown for the ditches on Table 2.05.3(4) -7 -2 <br />were from actual as -built information. On September 10, 2013 Lewicki and Associates responded to this <br />question and stated that the table reflected information derived from as -built surveys and that a note was <br />added to the table. This satisfied the Division regarding this matter. TR -04 was subsequently approved <br />on October 15, 2013. <br />AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER <br />A Touchstone Energy' Cooperative <br />CRAIG STATION ESCALANTE STATION NUCLA STATION <br />P.O. BOX 1307 P.O. BOX 577 P.O. BOX 698 <br />CRAIG, CO 81626 -1307 PREWITT, NM 87045 NUCLA, CO 81424 -0698 <br />970 - 824 -4411 505 - 972 -5200 970 - 864 -7316 <br />