ENFORCE37222

• Permit No: C1981041
• IBM Index Class Name: Enforcement
• Doc Date: 5/4/2001
• Doc Name: PETITION FOR HEARING EXTENSION OF TIME TO ABATE AND RESPONSE TO NOV
• From: SNELL & WILMER LLP
• To: DMG
• Violation No.: CV2001005
• Media Type: D
• Archive: No

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999
Snell &Wilmer
L.L.P.
uw oEElces
1200 Seventeenth Street, Suite 1950
Tabor Center
Denver, Colorado 80202
(303)6342000
Fax: [phone]
Robert D. Comer [phone]
Intemen rcomet®swlaw.com
Mr. Mike Long
Division of Minerals and Geology
1313 Sherman Street, Suite 215
Denver, CO 80203
Mined Land Reclamation Board
1313 Shernian Street, Suite 215
Denver, CO 80203
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Via e-mail and hand-delivery
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Re: NOV # CV 2001-005
Petition for Hearing, Extension of Time to Abate and Response to NOV
NOV # CV 2000-010
Supplementation of Pleadings
Dear Mr. Long and Members of the Board:
This firm represents Powderhom Coal Company ("Powderhom"). Powderhom is a debtor
in possession having filed a petition in bankruptcy (Chapter 11) in [he United States Bankruptcy
Court for the Eastern District of Kentucky. Poa~derhom's banknlptcy case is administrated with
the bankruptcy case of its parent, Quaker Coal Company ("Quaker"), and 18 other subsidiaries of
Quaker.
On December 14, 2000, Powderhom received a Notice of Violation from the Colorado
Division of Minerals and Geology (the "Division") with respect to Reclamation Bond # I OS4SG
(the "Bond"), which Powderhom had obtained from Frontier Insurance Company ("Frontier")
for its mine located near Cameo, Colorado (the "Powderhom mine"). The DMG based the NOV
on a finding that the United States Department of the Treasury had revoked the certificate of
authority issued to Frontier pursuant to 31 U.S.C. y§9304-9308. The period to abate the NOV
has been extended until May 31, 2001, unless terminated prior thereto. Powderhom responded
to the NOV on December 29, 2000 and March l4, 2001, and hereby incorporates those
documents and any other documents pertaining thereto in this Response. A hearing on the NOV
is scheduled for the May meeting of [he Mined Land Reclamation Board (the "Board").
Member. LEx AIU NDI, a global association or indrpeWenr law lima wnh members in
the United Smfes and 60 counlnes ~hrouglmm the world.
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MAY 0 4 2001
IBlrislon of Mlnerels and Oeolopy
May 4, 2001
Snell Ct W rimer is a member o(LeS nfutvnl, a leading assoiianon n( mdependenr law Emu