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_ III IIIIIIIIIIIIIIII <br />SLURCO CORPORATION <br />P.O. Box 281304 <br />LAKEWOOD, COLORADO 80228-9304 <br />OClobef 24, 1994 Telephone: (303) 990-9340 <br />RECEIVED <br />Mr. Mike Long, Director <br />Colorado Division of Minerals and Geology OCT 26 1994 <br />215 Centennial Building <br />1313 Sherman Street Division Ot Minerals d (neology <br />Denver, CO 80203-2273 <br />RE: Request for Vacation of Notlm of Vloletlon C-94-027, Canadian Strip Mine, Perm(t C-81-026 <br />Dear Mr. Long: <br />On September 27, 1994, Mr. David Berry (during an oversight inspection with Mr. Elul Pugh with OSM) <br />issued the above referenced Notice of Violation (NOV) for failure to provide evidence that certain <br />impoundment quarterly inspections were conducted by a qualified registered professional engineer or a <br />qualified individual under their direction, and failure to provide the reports to the Division by a registered <br />professional engineer. Slurco Corporation hereby requests vacation of the above referenced NOV for the <br />following reasons: <br />1. The attached documentation from our engineer indicates that he conducts an annual pond inspection and <br />certification. Further, that other quarterly inspection reports for 1992 and 1993 were reviewed by him <br />during preparation for his annual inspections. <br />2. During Company reorgartiTation as referenced by the transfer of ownership in 1991, all corporate <br />professional engineers who were in charge of certifications left the Company. As a result, no <br />documentation can be obtained for that time period. However, Slurco contends that all inspections were <br />conducted under the direction of a professional engineer. <br />3. Similar proceedures for conducting quarterly pond inspections and reporting have been conducted since <br />the mid 1980's. The Division and OSM have conducted numerous inspections of the site and records <br />during that time period and no questions concerning this issue have ever been raised. In fact, Slurco is <br />aware of several other coal mines in the State of Colorado where the operators are conducting similar <br />procedures referenced to be in violation as described in this NOV. <br />Slurco's methods of conducting and reporting quarterly pond inspections have been consistent over the past <br />ten years and have been under supervision of registered professional engineers. These proceedures are also <br />consistent with other mines in the State operating under the same set of rules and regulations and their <br />interpretations. In addition, the mine was completely reclaimed in 1987 and the sediment control system was <br />removed in 1992. As a result, the site has been deemed to have sufficient vegetation to control erosion and <br />the remaining two retention ponds were kept to provide water for grazing and wildlife. <br />