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- - -- ~ • ! iii iiiiiiiuiiu iii 999 Western Associated Coal Corp. Suite 2300 470 Seventeenth Street Western Denver, Colorado 60202 ®® (303)625-1966 July 22, 1983 Ms. Carol Russell Reclamation Specialist Colorado Mined Land Reclamation 1313 Sherman Street Denver, CO. 80203 Re: N.O.V. 83-19, Blue Ribbon Permit IrC-047-81 Dear Ms. Russell: ~~~1 ~~~ .~UL ~ 51983 f:11NF® LANrJ RECLA ~1ATIQN Ccle. Gep?, of,)etural Rescurce~ As you are aware, Western Associated Coal Corp. is the managing agent for Blue Ribbon Coal Company. I have reviewed a copy of N.O.V. 83-19 and the related facts. Due to the small assessment of civil penalty, we submit this letter in lieu of attendance at a conference, if this is acceptable. I am frankly amazed that Blue Ribbon Coal Company would be - found negligent in its handling of this matter, as I understand it. If MLR chooses not to void this N.O.V., we would then want to discuss the' matter in a meeting. / Larry Reschke, our mine engineer, advises me of the following: "Subsequent to our phone conversation (Reschke-Russell) in early June concerning N.O.V. 83-19, I was under the impression that the N.O.V. had been voided, rather than just the "topsoil" removal requirement t•` having been dropped. Therefore, no additional information was submitted ~ l~, prior to the assessment on the N.O.V. When the assessment arrived, we ,,~~~ decided to ask fora conference to allow further discussion on the d N.O.V. I suggest a letter, rather than a meeting, as a cost saving measure for ourselves and 1dLR. Two points that we wish to discuss further are (1) the urgency of the situation and (2) the classification of the material as topsoil. Hubbard Creek, as with most other drainage systems in the area, recently had its highest flow in many years. Near the peak flow, Hubbard Creek began eroding the north embankment of Blue Ribbon's I<1 Pond. As normal, the creek is highest at night, and that is when the problem was discovered. To remedy the situation, material was taken from the inside edge of a wide part of the embankment, dumped in the hole being formed, and rock placed on the outside of the new fill. For non-technical personnel on afternoon shift, thoughts are to protect the property with what is readily .hand,-rather than to wait until morning when they can contact ~ MLR fort value judgment on the material proposed for use. Much delay could have caused the entire pond to wash out, including the "topsoil" used for fill. On the question of topsoil, non-technical personnel are trainable with respect to topsoil stock piles and topsoil in undisturbed areas, but to make a topsoil judgment at night in a pond embankment is ~- <ti ~~ - r ~I~J ,. -continued-