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III IIIIIIIIIIIIIIII STATE OF COLC>1~Uv DIVISION OF MINERALS AND GEOLOGY Depanment or Natural Resources I ] 17 Sherman St., Rpom 21 5 Derner. Colorado 80201 Phone: 13031 8h6-1561 FA,X: 13071 832.8 I06 Auwst 22, 1997 Mr. Phil Schmidt Mountain Coal Company PO Box 591 Somerset, CO 81434 RE: Nest Elk Mine Facilities within Sylvester Gulch, File C-80-007 Dear Ivir. Schmidt: Roy Ramer Governor lames 5. Lochhead E,.ecuuve Director Michael 8. Long Division DirecrOr Thank you for meeting with me on August 20,1997 to discuss your letter dated August 1, 1997, which responds to my July 25, 1997 order for a revision to the Mountain Coal Company (MCC) permit. Your letter refers to six attachments. Both the faxed and mailed versions of the letter contained only five attachments. If there is an additional attachment which you would like me to consider please let me know as soon as possible. As part of my review of your response, including the various attachments, I have also carefully reviewed Exhibit 69 of the MCC permit and the weekly field monitoring reports which MCC has submitted for the time period of May 27 -August 11, 1997. As we discussed earlier this week, in general I agree with your assertion that MCC has a methodology in place to respond to actual conditions encountered during construction of the Sylvester Gulch facilities. I do not find, however, that MCC has implemented the plan completely or appropriately in all instances. To summarize, your Construction Approach and Monitoring Prograzn methodology includes four basic parts, as follows: • collect additional geotechnical data and prepare additional slope stability analyses prior to construction, • conduct detailed 5eld monitoring of construction activities and results, • use top-down and benching construction techniques and control surface and ground waters to minimize or mitigate potential for slope failures, • perform redesign and slope failure mitigation activities as required to ensure long-term stability. The presumed advantage to having the Construction Approach and Monitoring Program in place is to allow MCC to respond in a proactive manner to the rigors of the construction project within Sylvester Gulch, learning from any failure situations and adapting methods and assumptions in order to avoid future failures. The Division approved the program with the intent to prevent environmental damage and ensure successful reclamation. However, it is not appazent that a