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<br />~~I'I~II~II~I'~~ II~ <br />sss <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department o(Natural Resources <br />1713 Sherman SI., Room 215 <br />Denver, CO 80203 <br />Phone: (7071 866-3567 <br />FA%: 1303) 8328106 <br />October 13, 1993 <br />Ms. Kathleen G. Welt <br />Environmental Supervisor <br />Mountain Coal Company <br />West Elk Mine <br />P.O. Box 591 <br />Somerset, CO 81434 <br />Re: Review Process, Technical Revision No. 65 <br />Permit No. C-80-007 <br />Dear Ms. Welt: <br />pF' [O~ <br />~~~ <br />„~'i <br />0 <br />~ /Bl6 <br />Roy Romer <br />Governor <br />Mirhael g. Long <br />Division Director <br />This letter is written to address some concerns which you relayed to me during our telephone <br />conversation of October 4, 1993 (approximately 10:00 a.m.). During that conversation, you <br />requested immediate approval of Technical Revision No. 65, and you indicated that our review <br />process had involved unnecessary delays and unnecessary focus on minor details. <br />These statements, and the underlying perceptions, are of concern to us. Our staff is dedicated <br />to performing our duties in as expeditious a manner as possible. Our employees are devoted to <br />their jobs, and we frequently work considerable overtime hours to ensure that operator sub- <br />mittals are reviewed properly and quickly. <br />On August 20, 1993, Christine Johnston and I met with you, Mr. John Poulous and <br />Mr. Steve Kessler regarding the Mountain Coal Company TR-65 submittal. At that time, you <br />expressed the urgency related to that submittal, and we committed to mobilize all available <br />resources to ensure a timely review. In fact, Ms. Johnston's workload was prioritized such <br />that all TR-65-related submittals would receive her immediate and undivided attention. Other <br />projects were shifted to other team members. We aggressively implemented our commitment <br />to Mountain Coal Company from start to finish. <br />Please Lnderstand that our staff reacted to approximately 23 different TR-65-related submittals <br />from Mountain Coal Company between August 20, 1993 and October 1, 1993. As discussed <br />during our August 20, 1993 meeting, and as acknowledged by you during our October 4, 1993 <br />telephone conversation, TR-65 approval was largely dependent upon the completion of TR-64. <br />Essential information regarding TR-64 did not arrive until well after the submittal of TR-65. <br />Ms. Johnston spent numerous hours on the telephone with various company and consultant <br />contacts in an attempt to resolve serious deficiencies in the submittals provided. Of utmost <br />concern were the sediment control plans. The concerns were not trivial in nature, but rather <br />fundamental requirements for which we had received either inadequate or no detail. As you <br />know, the fundamentals of sediment pond design and construction are of crucial importance, <br />