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~~i 1 <br />`~!r. Uave Shelton -?- Dec ember o, 1984 <br />uonu. Tne orainage was diverteu on the site by a previous operator. American <br />Fuels assumed responsibility for restablisning r,;,e drainage when they <br />succeeded to the permit. <br />However, they have not sub~aitted the additional bond. I discussed this <br />situation last with Raymond Wiley during riy September [5, 1984 inspection. <br />An additional $7,485.00 was requested on November 9, 1984 for final approval <br />of a revision application which would add two sediment ponds and associated <br />ditches. We asked that this $7,485.00 bond be submitted by <br />December 10, 1984. This accrues to a total of $17,185.00 required to <br />completely cover the terms of their permit approval. <br />I have made a rough estimate of reclamation costs of the site as it currently <br />exists. My calculations estimate that 42,319 would be required to reclaim the <br />site as it exists today. We will be issuing a cessation order this month to <br />prevent continued mining. This amount does not include the cost for <br />restablishing the drainage or any of the activities proposed in the sediment <br />control revision. Therefore, the true cost of reclaiming the site should be <br />estimated at $42,319 + $9,700 = $52,019. This indicates that our current bond <br />of $58,073.00 should be sufficient to reclaim the site. <br />Dave - it is my perspective that there are two main factors which have <br />affected their lack of compliance. I am not herein offering excuses, rather <br />insight into root causes for their lack of compliance. <br />One factor is inexperience and ignorance. There are basically three <br />individuals who make up the company. None of these three knew anything about <br />operating a coal mine in Colorado before acquiring the site. <br />The second factor is finances. At the onset the company had money to hire <br />good people to run the site. Thus the CMA award last year for such good <br />reclamation. However, early in 1984, for whatever reasons, the money ran out, <br />the mine shut down and the good people Left. Hence their problems began. The <br />three company owners are willing but unable to maintain compliance. <br />Due to their inexperience I doubt that they realize that they are risking <br />permit revocation. It may therefore be appropriate to discuss this <br />possibility with them and to allow the administrative process to be completed <br />on NOV's C-84-157, 164, and 165, before the Division proceeds further. <br />If and when we do proceed with a show cause action I am unable to decide <br />whether to recommend suspension or revocation. In the case of suspension, we <br />may allow them one last chance to get the site reclaimed without having to do <br />it ourselves. In the Case of revocation, we would be putting an end to their <br />struggle and then proceed with reclamation ourselves. I am unable to choose <br />the better route at this point. <br />If you want to discuss any of this further let me know. <br />/fw <br />Uoc. No. 5820 <br />