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~ _. <br />~ III IIIIIIIIIIIII III ~ <br />PANORAMA RESOURCE SERVICES. INC. <br />Geologists, Engineers & Permittera <br />1675 Lorimer Street, Suite 750 <br />Denver. Colorado 80202 <br />303-629-7390 <br />November 14, 1984 <br />Mined Land Reclamation Board <br />Colorado Department of Natural Resources <br />1313 Sherman St., Room 423 <br />Denver, Colorado 60203 <br />Dear Hoard Membersa <br />I, preg Lewicki of Panorama Resource Services, Inc., am <br />representing Trinidad Haain Mining,.Inc. concerning its Show <br />Cause Order of October, 1984. <br />I am a professional engineer with considerable experience in mine <br />permit design, construction and ongoing compliance. I have <br />worked hard to establish a good relationship with all state and <br />federal agencies dealing with coal companies in the Rocky <br />Mountain area. <br />In early September, 1984, I was hired by Trinidad Basin Mining, <br />Inc, to evaluate their permit compliance situation. After <br />reviewing the data and inspecting the site, it was evident that <br />the operation was suffering from one major problemo a poorly <br />designed and maintained sediment control system. Far a mine with <br />a disturbed area of SOb acres, 27 sediment ponds had to be <br />constructed, certified, maintained and sampled...not to mention <br />miles of collection and diversion ditches. The designs were not <br />practical for a mine with only a handful of employees. <br />Furthermore, the engineer who was responsible for overseeing the <br />situation was located in Kentucky and could not always identify <br />immediate problems and rectify them. All the ingredients were in <br />place for a string of violations and this is exactly what <br />happened. <br />The violations in th• past twelve months cannot be disputed but I <br />do feel that the operator wanted to do what was required to <br />comply, however, the complexity of the sediment control system as <br />designed, and the lack of on-site guidance, made things <br />difficult. <br />On October 26, 1964, I submitted a revision to the sediment <br />control system which would eliminate 14 to 16 ponds and <br />considerable lengths of collection ditches. Upon approval and <br />