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/~ f ACZ Inc. <br />~~~~~~"~ Engineering end Environmental Services <br />1475 Pine Grove Road, Suite 109 <br />P.O. Box 77401 B <br />Steamboat Springs, Colorado 80477 <br />303-879-6260 <br />April 23, 1993 <br />Mr. Randal] P. Price <br />Reclamation Specialist <br />Office of Mined Land Reclamation <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />III IIIIIIIIIIIIIIII <br />999 <br />Re: Kerr Coal Company - Marr Mine (Permit No. C-80-006), Records Requirements <br />Dear Mr. Price: <br />As you are aware, a records violation was issued to Kerr as a result of the recent joint <br />OMLR/OSMRE joint inspection. As indicated by the accompanying letter, several of the items <br />noted in the NOV were actually available at the mine but were not in the materials provided <br />for review due to the organization of Kerr's filing system. <br />Given the concern noted in Kerr's letter relative to "instant accessibility of information" we are <br />faced wi[h two fundamental problems; 1) Organization of permit and compliance files so [hat <br />the required information is readily accessible and can be located wi[h a minimum of searching; <br />and 2) Identification of °required information'. <br />Relative to the first problem, if we are realistic, no filing system is perfett and none can provide <br />°instant access". I believe this is probably as true of Kerr's files as it is of OMLR's or ACZ's. <br />This is why the "immediately available" provision of Rule 5.02.4 is no[ very practical or realistic. <br />Given, however, the desire to be able to find relevant information with a minimum of searching, <br />ACZ is working with Kerr to organize and upda[e the permitting and compliance files <br />maintained at the mine site. Coupled with improved organization, it may be more realistic for <br />inspectors to identify those documents or specific items they wish to review when they first <br />arrive at the mine site, then to proceed with their field inspection, allowing reasonable time for <br />[he operator to locate and provide the requested information for review following field activities. <br />Given the rather broad language of Rule 5.02.4, it is unclear exattly what information is <br />required co be maintained a[ the mine site. In order to assist Kerr and ACZ in organizing and <br />main[aining [he mine permit and compliance files we respectfully request tha[ OMLR provide <br />a listing of the items required to be maintained at the mine site. <br />We appreciate your consideration of these suggestions and your assis[ance with the requested <br />listing. Please feel free to contatt me if you have any questions. <br />Sincerely yours, <br />ACZ Inc. <br />Jerry! Nettleton <br />JMN:cmc <br />cc: D. Berry/OMLR <br />H. Austin/OSMRE-AFO <br />G. Patterson/Kerr <br />