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Ms. Erica Crosby <br />September 4, 1996 <br />Page 4 <br />Then when you telephoned me in the afternoon on August 29, you said <br />that the Division was issuing a violation for the work done on RCR <br />27A. The Division felt that this work should have been included in <br />a revision and added to our permit area. On Friday morning August <br />30, Roy Karo and I had a telephone discussion with Larry, about the <br />circumstances surrounding this violation. You arrived at the <br />minesite and issued NOV No. C-96-017. <br />The nature of the NOV included: <br />1. Failure to conduct mining operations within the permit area <br />(RCR 27A). <br />This road has never been in the permit area and at numerous times <br />since I have been at Seneca, over the last two years it has always <br />been discussed, but the end result is that it was not necessary to <br />include it. <br />2. Implementing revisions prior to approval (RCR 27). <br />The fill work alongside RCR 27 has been done within our easement <br />area, with the approval of the appropriate Routt county officials, <br />and is similar to the extra safety lanes at the intersection of RCR <br />27 and Yoast Haul Road "A". Those extra lanes are not in the permit <br />area, yet the Division had no problem with us constructing them per <br />Routt County specifications. <br />3. Failure to provide specifications and geotechnical analysis on <br />the road cut (RCR 27A) and failure to provide a reclamation <br />plan (RCR 27A). <br />This is a county road which we have utilized and maintained for <br />twenty-eight years. It has never been included in the permit area. <br />Mr. Paul Draper did not request road specifications, geotechnical <br />analysis, or a reclamation plan, on the widening being done to RCR <br />27A. He has worked with us over the years and was confident that <br />the work done on RCR 27A would be exceptional and that after the <br />dragline deadheads past RCR 27A, the road itself will be left in <br />better condition. <br />The preceding information provides a history of the circumstances <br />involving this deadhead project and the issuing of the violation. <br />Again, please review this violation quickly so we can have a <br />conference to discuss NOV Nos. C-96-015, C-96-016, and C-95-017 as <br />soon as possible. Please contact me if you or any other members of <br />the Division have any questions regarding this information. <br />