2014-12-22_ENFORCEMENT - C1981022

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�CIG��22- OXBOW MINING, LLC 3737 Hwy 133 P.O. Box 535 Somerset, Colorado 81434 USA Tel (970)929 -5122 Fax (970)929 -5177 December 19, 2014 Mr. David Berry Coal Program Supervisor Colorado Division of Reclamation, Mining and Safety 1313 Sherman Street, Room 215 Denver, CO. 80203 Re: NOV No. CV- 2014 -008 Submittal of Written Information Dear Mr. Berry: AEG 2 ZJp14 Elec\ama�%oo4 I Sated Oxbow Mining, LLC, Elk Creek Mine received Service of Process of the referenced NOV on Friday, December 12, 2014. The purpose of this letter is to provide additional information regarding the NOV (per Rule 5.04.3(1)). General Comments: The NOV relates to the 1) methane drainage or gob vent borehole programs of the Elk Creek Mine and 2) the mine recovery, gas monitoring and dewater boreholes installed to aid in the failed mine recovery efforts. Overall Oxbow is very proud of the GVB program associated with the Elk Creek Mine. Many of the drill pads and light use roads are located in some of the most extreme, steep terrain and facility construction and subsequent reclamation has been challenging but very successful. Emergency mine recovery borehole efforts involved the construction and completion of roads, drill pads and boreholes in extreme late winter /early spring conditions that presented difficult operational conditions. Unfortunately, much of this construction occurred when there was 4 feet of snow on the ground and conditions were not optimum. Overall, we believe it is important to note there was no environmental damage, and no offsite impacts. The alleged violations share less substantive but more administrative type errors in application of the Rules. Many of the failures were paper violations and administrative in nature. Oxbow is pleased to provide the following discussion regarding each Abatement Step as it relates to the apparent related Nature of Violation. • Page 1