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t <br />PAGE TWO <br />JANUARY 31, 199 <br />Please note WFU's comments on the NOV's. <br />DMG has always been informed of the pond inspections through the records kept at the mine. <br />Western Fuels (WFU) has been submitting certified inspection reports on only DP-1 since the <br />inception of the mine. DMG never objected to or asked for the annual certified reports on other <br />ponds. In order to comply with the NOV, WFU mailed the required certification to DMG on <br />December 22, 1993. The NOV has been terminated. Since this was purely a matter of paperwork, <br />and it has as been satisfied, WFU requests that the NOV be vacated. <br />The south side diversion of RDA 2-3 and the north side diversion of RDA 4 have been properly re- <br />established including riprapping of sections difficult to reach by a dozer. The work was performed <br />shortly after the non-compliance was brought to WFU's attention. WFU has recently submitted <br />permit renewal documents where a request has been made that the ditches be required to be <br />riprapped only if the runoff velocity exceeded four feet per second. Otherwise the ditches will be <br />seeded. The RDA-4 ditch will be either seeded or riprapped according to this plan once the <br />technical revision application submitted in concert with the permit renewal process is approved by <br />DMG. <br />WFU has been submitting applications for small area exemptions as such areas are being identified. <br />DMG is well awaze of this. WFU has devoted a separate section and will submit a separate map <br />for the small area exemptions with the technical revision application submitted with the permit <br />renewal document. WFU will implement the plan within 30 days of its approval. WFU requests that <br />this NOV be vacated since the regulations have been interpreted very subjectively and been applied <br />retroactively to items approved and found satisfactory in the past. <br />WFU has endeavored to comply with the approved permit document by compacting the refuse in <br />lifts not to exceed 2 feet and maintaining the 90% or more of the maximum dry density. No seepage <br />or stability problems have been noted in any of the refuse piles. The NOV required that WFU <br />