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III IIIIIIIIIIIIIIII~ <br />999 <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1313 Sherman St.. Room 215 <br />Denver, CO 80203 <br />Phane~ 1303) 866-3567 <br />FA%: (3031 832-8106 <br />Date: October 20, 1993 <br />To: Assessment Officer <br />From: Kent Gorham <br />Re: NOV C-93-137, Foidel Creek Mine, Permit No. C-82-056 <br />Please review the attached document first, then this memo prior to assessment. <br />pp coop <br />.s`~ <br />~~i <br />• ~ ~B]fi <br />Roy Romer <br />Governor <br />Michael B. Lang <br />Drv¢ion Dneaor <br />Issue No. 1: The Rule reads, "Monitoring...sha// be performed at /east quarter/y commencing <br />one month prior... " -not within 30 days as TCC has interpreted. <br />Issue No. 2: Recollection of my discussion with Mr. Middleton was that nine days lapsed in <br />the time frame of concern. Further review indicates that 15 days had lapsed <br />between surveys (more than two weeks). Noting in hindsight that the missing <br />data is not significant is irrelevant. The permit requires weekly surveys for two <br />months. <br />Issue No. 3: The surveying of line A-A' is required to adequately define the angle of draw. <br />Choosing which monuments to monitor requires prior knowledge of what the <br />exact angle of draw for that panel would be. In fact, TCC verifies and the data <br />indicates that the angle of draw was much greater than predicted. The permit <br />requires line A-A' to be surveyed, not some pre-determined subset. <br />Issue No. 4: The operator is mistaken. Rule 2.05.61611c1(EI requires the operator to submit <br />the results of the monitoring program to the Division at least semi-annually. A <br />reasonable presumption is submittal four to six weeks after the reporting period. <br />If the operator would like, we would reasonablelexpect the report to arrive six <br />months after the previous report. The previous report was received <br />March 3, 1993. This final report was received September 28, 1993, almost <br />seven months after the previous report. The abatement of this violation will <br />establish a firm date for submittal similar to other required reports. <br />Note: This data is being collected in conjunction with the subsidence of Fish Creek AVF. As <br />you might imagine, it has considerable significance to both Twentymile Coal Company <br />and the Division. There is no room for missing or erroneous data. <br />m:\oss\bjw\kep.nov <br />