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of this report to MIRD. AFO received a copy of the MLRD draft MOU with SHPO and requested a copy of MLRD's MOU with the Division of Wildlife. A copy of WFO's study on the Colorado Blaster Certification Program was also given to MI.RD. This was also a favorable report with minor improvements suggested. AFO requested that this report be forwarded to Joe Nugent of the Colorado Division of Nines. o Permissibility of Liability Self-insurance Under Colorado's Program The Meeker Area Mine has a certificate of insurance indicating that the mine is self-insured. AFO believes that self-insurance is not authorized under Colorado's approved program. AFO had previously discussed this with MLRD's Mike Long, who indicated that an Attorney General's opinion held that self-insurance was permissible in Colorado. AFO believes that self-insurance would be allowable Sf appropriate regulations were promulgated for the State program. The self-insurance question will be incorporated as an element of the 1991 annual report workplan. o Coal Basin Permlt Renewal - AFO's files were lacking the permit renewal document, and MLRD agreed to send a copy. The permit was renewed on May 31, 1988, and expires May 30, 1993. o AVS Checks - AFO requested that MLRD try an AVS check or investigate other documentation that may point to a corporate link between Flatiron Coal Company and Soldier Creek Coal Company, which operates a mine in Utah. o Citizen's Concern Regarding Terror Creek Loadout - AFO gave MLRD a copy of an AFO telephone log which recorded a citizen's concern about coal dust from the loadout's conveyor. The phone conversation was logged by AFO in December 1989, and it appeared that the concerned party had probably never elevated the concern to a formal, written complaint with MLRD. A formal complaint was not made to AFO either, although the AFO Specialist in December recommended that the citizen contact EPA. AFO suggested that MIRD check its files to be sure whether or not a formal complaint to MLRD had ever been made by this citizen. However, it appears at this time that a citizen's complaint probably had not been made to MLRD and that AFO's referral of the concern to EPA is probably sufficient action. o Small Area Exemption at Energy No. 3 - AFO expressed concern that a rock-filter ditch or collector at the SAE for the Middle Creek Office area may not provide sufficient treatment for oil and grease draining from the parking lot. MLRD believed that a showing of appropriateness was made in the permit for this rock filter in regard to effluent limitations. AFO should have these documents for updating the MRP. 4