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a - i 5731 Steta Highway 13 t S III IIIIIIIIIIIII III O ~ /I o O Meeker, Colorado 81641 ~f (303)624-0451 COAL ~ RECEIVED (303)6244459 FAX `~ COMPANY LP. D -f0-~~-IIOD~ENENO MAY 0 8 1995 An alliliate of Kennecott Energy and Coal Company Division of minerais a. (ieoiogy May 3, 1995 Mr. Mike Long Division Director _ . Colorado Division of Minerals and Geology 215 Centennial Building 1313 Sherman Street Denver, Colorado 80203 RE: Permit C-81-019, Colowyo Coal Company L.P. NOV C-95-005, Additional Information Dear Mr. Long: The attached information is submitted as additional information regarding NOV C-95- 005. We principally intend to clarify what we believe are inaccuracies contained in the April 27, 1995 Division Memorandum from Erica Crosby to you addressing the NOV and our request for a Vacation of the NOV. Colowyo also appreciates very much the opportunity to be involved at this early stage of the NOV review process. Second Paraaraah, first oaoe -The Division's statement that "the topsoil pile slid into the West Pit Sediment Pond" is a misleading over-statement of the facts. Rather, a portion of the topsoil stockpile is located on top of a block failure, the toe of which is bulging into the pond. While we agree this is a previously non-existing, naturally occurring slide located on the inside of the pond (not on the embankment) principally caused by perched groundwater, the topsoil stockpile has not "slid into the pond". Item #2, second oaoe -The June 21, 1994 DMG inspection report and the Colowyo January, 1995 West Pit Fill construction report both describe the remediation of a slide area and installation of a frenc'r1 drain in the vicinity of the buttress fil! and r^c!: underdrain for the West Pit Fill. There appears'to be some confusion on the part of the Division as to the source of the topsoil from this activity. In both instances the topsoil referred to in the documents refers to topsoil removed as part of the specific slide repair activities and not the topsoil stockpile located adjacent to the pond. There is considerable distance separating these two distinct areas, perhaps a minimum of 200 feet. Moreover, since construction of these fill lateral drains occured nearly a year after location and placement of the topsoil stockpile, we disagree with the Division's conclusion that Colowyo should have been aware of probable instability in the location of the stockpile based upon these subsequent fill activities. Item #3, second oaoe - As noted above, the June 1994 slide repairs and lateral drain construction were associated with the fill construction, not with the topsoil stockpile located some distance away. Based solely upon these fill activities, we had no way of predicting nor was there any evidence to suggest future instability associated with the pond.