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iii iiiiiiiiiiiii iii ENS O, ~ ar,~ ~ RF a ti" United States Department of the Interior a OFFICE OF SURFACE MINING RECLAMATION AND ENFORCEMENT "''^" ~~ "'° 219 CENTRAL AVENUE, NW ALBUQUERQUE, NEW MEXICO 87102 February 1, 1984 Mr. Fred Banta Supvervisor, Coal Section Mined Land Reclamation Division 423 Centennial Building 1313 Sherman Street Denver, Colorado 80203 Dear Mr. Banta: RECErVEp FEB C 1984 MINED LAND RECIAMATiDtd CIVtS10N Colo. Dept, of Natural Resources I still have a number of concerns about the Trailer Park at Sundance Coal Company's Animas mine that were not settled by your letter of January 17, 1984. Topsoil removal and protection remains in question. Your letter implied that topsoil was removed from the disturbed area and remained to be removed from a larger area proposed in the revision. The letter states that "topsoil had been pushed aside to create several pad areas" and that the "revision indicated that a larger area would be impacted than the original disturbance and additional topsoil would be salvaged." Your original NOV #83-4 cited the "failure to salvage and protect topsoil" and the accompanying Division report stated that the company had "failed to salvage and/or adequately protect in-place top- soil" and to "maintain approved measures to stabilize and protect stockpiled topsoil." According to your staff, the third stipulation of revision approval required the operator to submit to you topsoil analyses from the trailer park area before stripping it to a depth of 22 inches. Con- versations with your staff have showed that, in all probability, most of the existing .topsoil at the disturbed trailer park area has not been salvaged. Another point raised in the letter was that a management change at the mine shifted emphasis toward reclaiming the trailer park area. OSM is unaware of a formal approval by the MLRD to rescind the revision. At the time MLRD was advised of this change in plans, the Division should have initiated different action to accomplish reclamation. If the revision was rescinded, OSM believes a management change in July or August 1983 would still allow time to reclaim the area in the fall of 1983, especially since the violations were formally brought to the company's attention and made a matter of record by the Division in February 1983.