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`i kerr coal company .; ~ ~,. box 487 ~ Walden, Colorado 80480 ~ 1303) 723-4721 - ~, April 23, 1993 Mr. Randall P. Price Reclamation Specialist Office of Mined Land Reclamation 1313 Sherman Street, Room 215 Denver, Colorado 80203 Re: Kerr Coal Company - Marr Mine (Permit No. C-80-006), NOV C-93-021 Abatement Dear Mr. Price: With reference to NOV C-93-021, Failure to Maintain Required Records at the Mine Site, issued April 6, 1993, I checked the permit files at the mine site immediately following the joint OMLR/OSMRE inspection [o determine whether or not the items noted in the NOV were actually missing. The results of this confirmation check are summarized as follows: 1) Map 28A shows the revised permit boundary approved during TR-09. S[a[us: A copy of Map 28A was no[ located at the mine site. A copy has been obtained from ACZ (4/14/93) and inserted in the permi[ file. 2) The NPDES permit had expired in June and there was no correspondence from the Health Department concerning a renewal. Status: Kerr filed an application for renewal of CDPS Permit No. COG850021 on December 3, 1991. A copy of the renewal application is on file at the mine site. Based on con[aas wi[h the Colorado Department of Health (CDH), the CDPS renewal was issued on June 15, 1992. Unfortunately, the renewal was transmitted directly to Kerr's corporate headquarters in Denver, with no copy to the mine. A copy of the permit renewal was transmitted to the mine (4/21/93) and inserted in the permit file. Kerr has requested that CDH copy the mine on al] future permit related correspondence. 3) The current bonding document was missing. Status: Documentation for the existing bond of $5.5 million is on file a[ the mine site and was made available at the time of the inspection. Correspondence rela[ing to the recent reevaluation of bond liability for the mine is also on file at the mine, including the March 16, 1993 findings letter from OMLR indicating a current reclamation liability of $4,510,644. This letter notes two outstanding items, powerline removal and the Pit 1 backfill volume, which have the potential to further reduce the bond amount. The only bonding related item not on file at the mine site is an amended bonding form extending bonding coverage to include OSMRE as well as OMLR. This document from OMLR was transmitted only to Kerr's corporate headquarters in Denver, wi[h no copy to the mine. Kerr has contacted OMLR, requesting that a copy of this document be provided [o the mine and tha[ the mine be copied on all future permit related correspondence.