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Mountain Coal Company West Elk Mine Post Office Box 591 Somerset, Colorado a1434 Telephone 970 929-5015 Fax 970 929-5595 August I, 1997 Ms. Susan McCannon Colorado Division of Minerals & Geology 1313 Sherman Street, Room 215 Dem~er, CO 80203 RE: West Elk Mioe Facilities -Sylvester Gulch Dear Ms. McCannon: ,~ ~II ~II~II~I~~~~I ~II sss RECE~`~ED AUG U 4 1881 Division of Minerals i£ Geology In response to your letter of July 25, 1997 to me that ordered Mountain Coal Company (MCC) to prepare and submit a technical revision application to address the operational and reclamation stability of the Cacilities being constructed in Syh-ester Gulch, i offer the following information for your considerauon. As discussed in the July 30th meeting with you and some of your staff, MCC believes that [he subject matter that }'ou want addressed in a technical revision application is already integral to the approved PR07 revision. MCC, its consultants, Dr. Pendleton and others of your staff have discussed various concerns with the stability of facilities in Sylvester Gulch from the very start of the PR07 permitting process. As a result, MCC and CDMG mutually developed a system to deal with actual conditions encountered during construction, perform reevaluation and redesign facilities as required, and apply actual ground characteristics to constrncted facilities. In addition, MCC has initiated significant geotechnical exploration and investigation of Sylvester Gulch. This program was approved by CDMG as Minor Revision 218 (MR218) and is underway. The objective of this program is to obtain additional ground condition design parameters. These parameters will be used to substantiate or redesign facilities projected for construction this year, and will also be used for design of future (acilities. Furthermore, MCC is providing regular communication to CDMG, including weekly reports (as agreed to in PR07). it was through this communication, in fact, that MCC alerted the CDMG of the stability issues at hand. The weekly reports describe the progress made in conswction, observations of surface and subsurface conditions encountered, data collection efforts, and information that may be of importance regarding the stability of facilities constructed, under construction, and projected to be constmcted. It is also in MCC's best interest that stable facilities are constructed in Sylvester Gulch. As agreed [o in PR07, this will require an approach that allows for adjustments to be made as construction progresses, and that the knowledge vve gain from experience and actual ground conditions is applied appropriately. For example, as a result of data collected on the failed fill area, MCC has taken the initiative to install additional instmmentation to measure pore pressures and movement under the large embankment that will be constructed across Sylvester Gulch. I have attached several documents for your review that indicate our commitments and the construction approach included in PR07. 1 am confident that these documents will satisfy your concerns and that you will find that a technical or any revision is no[ necessary. Please let me know if you require any further information regarding your concerns. Respectfully submitted, ~~ ~ ~~~~~ Phil G. Schmidt Engineering Manager Attachments: PR07 Second Response, No. 71, April 24, 1997; General conswclion approach and schedule for the SGFA; J. Pendleton memo to M. Boulay, Apri] 30, 1997; Letter to Mike Boulay responding to memo, April 30, 1997; MCC's response letter to Mile Boulay dated April 30, ] 997 addressing geotechnical concems; July 21 -July 27, 1997 Weekly Report. xc: Gene DiClaudio Chris Nyikos Christine Johnston Eric Mende Kathy Welt