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tititi ~u~~~i~~iii~ iii <br />STATE OF COLOI,~ ~~v <br />DIVISION OF MINERALS AND GEOLOGY <br />Deparlmenl of Natural Resources <br />I l l S Sherman $1., Room ? 1$ J <br /> <br />Denser, Colorado d0'U3 I~ <br /> <br />Phonc~ (3031 dbb-1567 I <br />FAQ 13031 dl'-4106 <br /> DEPARTMENT OF <br />July 2~, 1997 RESOURRCES <br />Ivir. Phil Schmidt <br /> <br />Mountain Coal Company <br />PO Box 591 Roy Romer <br />Governor <br />lames 5. LochheaA <br />E.ecueve Director <br />Somerset, CO 81434 Michael B. Loral; <br />Division Director <br />RE: West Elk Mine Facilities within Sylvester Gulch, File C-80-007 <br />Dear Mr. Schmidt: <br />I have reviewed the enclosed inspection report, issued by Michael Boulay and Jim Pendleton of <br />the Division staff. This report documents their observations and inspection of the West Elk Mine <br />site on July 9 &10, 1997. As a result of that inspection, also enclosed, please find two Notices of <br />Violation. One NOV is issued for impacts to the hydrologic balance resulting from road berm <br />construction encroaching upon the Sylvester Gulch drainage. The second NOV is issued for <br />environmental impacts resulting from the mass instability of the hauUaccess road embankment <br />construction. Both of these enforcement actions are documented and described in further detail <br />in the inspection report. <br />Separate from the above enforcement actions, I am ordering that the West Elk Mine permit <br />sections which address operational and reclamation stability of facilities construction within <br />Sylvester Gulch be revised. The mass instability which has occurred eazlier this month in the <br />haul/access road cut and fill construction areas demonstrates that either the approved design and <br />construction parameters were not properly implemented on the ground, or the approved design <br />and construction pazameters were not adequate to guazantee stability of the resultant structures <br />and facilities. Based on our inspection and conversations with MCC staff we do not have reason <br />to believe that MCC failed to follow the approved design and construction pazameters. Rather. <br />we find that the design and construction pazameters submitted by MCC were not adequate to <br />guarantee stability of the resultant haul/access road cut and fill structure. We also find that all <br />the cut and fill structures and facilities to be built within Sylvester Gulch are based upon the <br />same design methodology and assumed construction parameters. Therefore, our concern about <br />inherent stability extends to all other cut and fill structures and facilities to be built within <br />Sylvester Gulch. Therefore, in accordance with Rule ?.03.3, [find that revision of the <br />geotechnical stability analyses for those structures and facilities is required at this time. Please <br />submit a revision which re-addresses the long-term operational and reclamation stability of those <br />structures in light of the fact that one structure has already failed. The technical revision should <br />be submitted as soon as possible, but no later than August 29, 1997. In order to assure that this <br />revision is prepared, submitted and reviewed in the most efficient manner, I strongly suggest that <br />