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g4il6lT TBM -1 PANORAMA RESOURCE SERVICES, INC. Geologists, Engineers & Permitters 1675 Lorimer Street, Suite 750 Denver, Colorado 80202 303-629-7390 November 14, 1984 Mined Lend Reclamation Board Colorado Department of Natural Resources 1313 Sherman St., Room 423 Denver, Colorado 80203 Dear Board Membersa I, Oreg Lewicki of Panorama Resource Services, Inc., am representing Trinidad Basin Mining, Inc. concerning its Show Cause Order of October, 1984. I am a professional engineer with considerable experience in mine permit design, construction and ongoing compliance. I have worked hard to establish a goad relationship with all state and federal agencies dealing with coal companies in the Rocky Mountain area. In early September, 1984, I was hired by Trinidad Basin Mining, Inc. to evaluate their permit compliance situation. After reviewing the data and inspecting the site, it was evident that the operation was suffering from one major problems a poorly designed and maintained sediment control system, For a mine with a disturbed area of 306 acres, 27 sediment ponds had to be constructed, certified, maintained and sampled...not to mention miles of collection and diversion ditches. The designs were not practical for a mine with only a handful of employees. Furthermore, the engineer who was responsible for overseeing the situation was located in Kentucky and could not always identify immediate problems and rectify them. All the ingredients were in place for a string of violations and this is exactly what happened. The violations in the past twelve months cannot be disputed but I do feel that the operator wanted to do what was required to comply, however, the complexity of the sediment control system as designed, and the lack of on-site guidance, made things difficult. On October 26, 1984, I submitted a revision to the sediment control system which would eliminate 14 to 1B ponds and considerable lengths of collection ditches. Upon approval and