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~,,,~~~ ~ ~~ ~y~,~ , ~-- IIIIIIIIIIIIIIII <br />Dorchester Coal Company <br />United Bank of Arapahoe Bldg. <br />Suite 300 <br />9350 East Arapahoe Road <br />Englewood. Colorado $01 I? <br />Writer's Direct Dial bomber <br />(303)779-6444 <br />November 23, 1982 <br />Mr. Dave Shelton <br />Colorado Mined Land Reclamation <br />1313 Sherman Street - #423 <br />Denver, Colorado 80203 <br />Re: Response to Violation 82-59 <br />Dear Dave: <br />N <br /> <br />,, , <br />_.:I_r~::.. , . ,~ <br />~•,~~. Dept. o! :. •,~ ,, :............ <br />This letter is written to provide your agency with additional information <br />upon which to consider the above referenced violation. On November 8, 1982, <br />Mr. Herron conducted an inspection at our Fruita Mine, noted what he felt <br />was unauthorized road construction and subsequently issued the violation. <br />A review of our files and discussions with personnel on site reveals the <br />following facts: <br />1) The road construction was, in fact, merely a widening of an old <br />road bed/trail in an area which had been disturbed prior to <br />Dorchester's activities. Some additional disturbance was <br />created when the drill rig had to be extricated from a muddy <br />spot. The total disturbance included a cut of less than 24 <br />inches in depth (in most of the area, less than 12 inches) <br />fora total distance of less than 200 feet. Maximum width <br />of the disturbance was 50 feet including the pre-existing <br />disturbance. <br />2) Regrading of the entire disturbance required less than one <br />hour of dozer time (including transit) and was ccmpleted oon <br />November 17, 1982 with seeding accomplished on November 19, 1982. <br />3) The road widening activity was undertaken in support of a <br />geotechnical drilling program designed to obtain foundation <br />characteristics to be utilized in designing and permitting <br />the proposed Fruita Mine. This drilling program was approved <br />by CMLR on November 5, 1982 as an amendment to our existing <br />exploration approval and as such, was covered by surety bonds in <br />the amount of $83,391. That amendment to our existing approval <br />included a map delineating such drill sites as well as a <br />narrative describinc the activities. <br />Dorchester did not anticipate new road construction in conjunction <br />with the geotechnical drilling program. Ho~•iever, minor disturbance <br />is expected in Conjunction with any drilling program and when <br />safety considerations dictate, road improvement must be undertaken. <br />We felt, and continue to feel, that such activity properly falls <br />A Subsidiary of Dorchester Gas Corporation <br />