APPCOR10205

• Permit No: C1981039
• IBM Index Class Name: Application Correspondence
• Doc Date: 12/18/1979
• Doc Name: ROCKCASTLE CO GRASSY CREEK COAL MINE #1 FILE #78-45
• From: RAYE & ASSOCIATE
• To: DNR
• Media Type: D
• Archive: No

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RAYE & ASSOCIATES
III IIIIIIIIIIIIIIII ~
Progress Wttltin E4rvironn(ental 7bleraatces
December 18, 1979 '~` ~~ ~
Mr. Rick Mills ui~4f ~ ~/,/(
Colorado Department of tJatural Resources ~~~ ~67 ~j.I'.
Mined Land Reclamation, Room 723 '~''" ~
1313 Sherman Street
Denver, CO 80203
Re: The Rockcastle Company
Grassy Creek Coal Mine bl
Your file N78-45
Dear Rick:
When the Rockcastle Company designed its mining operation and was granted a
mining permit in 1978, their haul road design showed them to be in compliance
with applicable regulations. However, on site development led to a minor vio-
lation of the OSM interim regulations. Section 816.152 of the final OSM reg-
ulations (there were no changes in this section from the interim regulations)
states: (1) the overall grade shall not exceed 100; (2) the maximum grade shall
not exceed 15~; and (3) there shall be no grade over 10% for any consecutive
300 feet.
A survey requested by the Rockcastle Company shows that the overall grade of
the last half mile of the haul road into pit B is 10.550• However, in no case
does any portion of the road exceed 15o - in fact, the greatest pitch for any
single hundred feet is 13.50• Also, the road exceeds 10% grade for more than
300 feet in two places. About four hundred feet after crossing Grassy Creek,
the grade increases to an average of 10.6 for the next 500 feet (with a max-
imum grade of 11.Oo). Then, near the pit entrance, the average grade is 11.So
for 800 feet (with the maximum being 13.50 for 100 feet). All other roads are
in compliance.
As you know, OSM cited the Rockcastle Company for this violation, but did not
consider it an offense warranting a penalty. OSM recognizes that correcting
this violation would disturb more surface than justified. However, the vio-
lation is in their records. In order to prevent future OSM inspectors from
citing the same grade violations, the Rockcastle Company requests that the
Mined Land Reclamation Board approve the existing grades as part of its mining
plan for the remainder of the mine life. The approved mining sequence shows
that the Rockcastle Company will not use any portion of the haul road that is
in violation beyond the second quarter of 1981.
Rick, I do not know how best to procedurally bring this to the Board's atten-
tion. Will you please discuss this with Dean Massey or Chips Barry as appro-
priate and then advise me. The Board may elect to issue a variance until [he
976 WELCH CiOURT GOLDEN, COLORADO 60401 [phone]