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III IIIIIIIIIIIII III STATE OF COL01~yU DIVISION OF MINERALS AND GEOLOGY Departmem of Natural Resources 1113 Sherman SL, Room 215 Denier, Colorado BO201 II~ Phone~13031 8fi6-356% FAI: 17031 83?-81 OL DEPARTMEfVT OF July 2~, 1997 ~ CE$ RE ~UR Mr. Phil Schmidt Roy Romer Mountain Coal Company Gueemor lanes s. Loihhead PO Box 591 Cteculiae Director Somerset CO 81434 hlichae~ e. Cong , Drvisum Director RE: West Elk Mine Facilities within Sylvester Gulch, File C-80-007 Dear Mr. Schmidt: I have reviewed the enclosed inspection report, issued by Michael Boulay and Jim Pendleton of the Division staff. This report documents their observations and inspection of the West Elk Mine site on July 9 &10, 1997. As a result of that inspection, also enclosed, please find two Notices of Violation. One NOV is issued for impacts to the hydrologic balance resulting from road berm construction encroaching upon the Sylvester Gulch drainage. The second NOV is issued for environmental impacts resulting from the mass instability of the haul/access road embankment construction. Both of these enforcement actions are documented and described in further detail in the inspection report. Separate from the above enforcement actions, I am ordering that the West Elk Mine permit sections which address operational and reclamation stability of facilities construction within Sylvester Gulch be revised. The mass instability which has occurred eazlier this month in the haul/access road cut and fill construction areas demonstrates that either the approved design and construction parameters were not properly implemented on the ground, or the approved design and construction pazameters were no[ adequate to guarantee stabiligr of the resultant stntctures and facilities. Based on our inspection and conversations with MCC staff we do not have reason to believe that MCC failed to follow the approved design and construction pazameters. Rather, we find that the design and construction parameters submitted by MCC were not adequate to guarantee stability of the resultant haul/access road cut and fill structure. We also find that all the cut and fill structures and facilities to be built within Sylvester Gulch are based upon the same design methodology and assumed construction parameters. Therefore, our concern about inherent stability extends to all other cut and fill structures and facilities to be built within Sylvester Gulch. Therefore, in accordance with Rule ?.08.3, I find that revision of the geotechnical stability analyses for those structures and facilities is required at this time. Please submit a revision which re-addresses the long-term operational and reclamation stability of those stntctures in light of the fact that one structure has already failed. The technical revision should be submitted as soon as possible, but no later than August 29, 1997. ]n order to assure that this revision is prepared, submitted and reviewed in the most efficient manner, I strongly suggest that