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Mountain Coal Company West Elk Mine Post Office Box 591 Somerset, Colorado 91434 Telephone 970 929-5015 Fax 970 929-5595 August 29, 1997 Ms. Susan McCannon DIVISION OF b1INERALS AND GEOLOGY Office of Mined Land Reclamation 1313 Sherman Street, Room 215 Denver, CO 80203 RECEIVED StN 0 81997 Divislcn et tl.iner2~` ~~ ~.eclo9y Re: West Elk Mine, Permit No. C-80-007, Sylvester Gulch Facilities Area Dear Ms. McCannon: Ill I~~I~~~f~ll~~ll~ Mountain Coal Company (MCC) appreciates your consideration of MCC's letter dated August O1, 1997, and your careful review of Exhibit 69 and various weekly reports that have been submitted to the Division. MCC has reviewed your subsequent letter, and provides the following response. Your first comment is in regard to the number of attachments that you'd received with hfCC's above-mentioned letter. All attachments were provided. The April 30, 1997 response letter from MCC was inadvertently counted az two attachments. I believe that MCC has complied with each commitment made in MCC's Construction Approach and Monitoring Program, but if we have failed, it is that we have not proven such to the Division. The following discussions are provided az documentation and support. MCC agrees with your summary of the four basic parts of MCC's Construction Approach and Monitoring Program, as well az the presumed advantages. The Division approved this approach and program "... [o allow MCC [o respond in a proactive manner, learning from any failure situations and adapting methods and azsumptions in order to avoid future failures." it is absolutely in the best interest of MCC, both economically and operationally, to construct and maintain stable and environmentally-sound facilities. As such MCC shares the Division's intent "... to prevent environmental damage and to ensure successful reclamation ..", and has the added objective of ensuring the long-term viability of this operation, including these crucial facilities under construction. During construction there will be instabilities -some may result in failures. The Division and MCC acknowledged this in the development of the construction approach. These instabilities and failures during construction aze not synonymous with envvonmental damage (i.e. just because there is a landslide does not mean that damage to the environment has been caused). Landslides are a part of the natural environment. Timing has been primarily "impacted", much like for the Jumbo Mountain slides. The slides were not created by this construction, but the riming of the slides may have been affected. MCC's approach in Sylvester Gulch is to address existing instabilities, whether the instability was evident prior to construction or not. MCC is resolving these instabilities for the long- term (with regards to reclamation az well) by both proactively and reactively designing and constructing these facilities. It is important to note that the Construction Approach and Monitoring Program, as defined in the original submittal, and also az referenced and agreed to in Dr. Pendleton's memo to Mike Boulay of April 30, 1997, is specifically focused on potentially unstable slopes. This program waz never intended [o be applied "in all instances" az alluded to in your letter, only to those areas where failures did occur or where previous investigations indicated stability problems were likely to occur (such az the lower Sylvester Gulch road). in the first bulle[ of the four basic parts of the approach and program lis[ed in your letter, MCC committed to performing additional geotechnical investigations and stability analyses. This haz been done for the substa[ion cut slope, the lower Sylvester Gulch road, and the Shaft X3 sites, in particular, and resulted in design modifications az brieFly described below. MCC has also,in fact, postponed the construction of the water tank road until additional geotechnical investigation and supplemental stability analysis are completed (but probably not this year).