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MS. ERICA CROSBY JULY 27, 1993 PAGE 3 "Refuse disposal area 4 -failing to divert surface runoff by locating a large sump on the refuse pile and not allowing for sufficient drainage". During the spring of 1993 a soft spot in the coal waste bank had been found. In order to continue to construct the coal waste banking refuse disposal area 4 in compliance with the regulation discussed above, Western Fuels personnel began the process of digging up the area in question to allow drying of the material and to recompact the coal waste bank. Once the material in the soft spot had been dried and recompacted, a depression remained. This depression was being eliminated by the addition and compaction of more refuse material. Please note that as demanded in the NOV, WFU constrcted a ditch in order to drain any water from the depression to the RP-4 pond. The ditch was constructed on July 1, 1993 during the miners' holidays. WFU incurred overtime payments to perform these tasks. Once the mine resumed its normal operation on July 13, 1993 the hauling of refuse from RP2/3 to RP4 began. The RP4 depression has now been filled in alongwith the temporary ditch constructed during the mine holiday. It is difficult, if not impossible, to remove and recompact under-compacted material without creating a temporary depression. This NOV can be viewed as a dis-incentive to remediate problem areas found after construction. Are good-faith efforts to meet or exceed regulatory requirements going to be penalized in the future? Surface water runoff had not accumulated in the depression at any time. There was no need for any diversion or location of a sump. Therefore, WFU asserts that a violation as stated did not occur. If you have any questions, or need additional informaiton, please call. Sincerely, r Murari P. Shrestha, P.E. Assistant Manager of Engineering MS:Igp cc: Raja Upadhyay Mike Weigand Jeff Dubert Tim Chervick