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~--- <br />~II ~I~II~II~~~~~~II <br />STATE OF COLUIZA~U <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />131 } 5hern-~Tn SI., Roam 215 <br />Denver, CO ft0203 <br />Phone: (303; 866-3567 <br />FAX:13031832~8106 <br />February 24, 1993 <br />Brian P. Dunfee <br />Manager, Environmental Affairs <br />Peabody Western Coal Company <br />1300 South Yale Street <br />Flagstaff, AZ 86001 <br />OF.~~[~ <br />a <br />~~~8 <br />o, <br />~? . <br />• 18]6 ~ <br />Roy Romer <br />Governor <br />mtichael B. long <br />D rvision Director <br />RE: Hayden Gulch Loadout (C-92-081) <br />Application Review, Preliminary Adequacy Concerns <br />2-10-93 Submittal: Incidental Boundary Change; Addition of Haul Road and <br />Truck Loadout; Appendix 12-3 (Road Requirements) <br />Dear Mr. Dunfee, <br />The Division has the following concerns and questions regarding your submittal <br />of February 10, 1993: <br />1. incidental boundary changes to the permit area will result in <br />changes to several maps. <br />Please submit these revised maps prior to final approval of permit <br />(as noted in Division's PAR of February 19, 1993 (~ 6)). <br />2. Section 1.04(111) defines the term "road", as well as, haul road, <br />access road and light duty road. A discussion took place between <br />representatives of the Division and Peabody West on February 10, <br />1993 in which the status of several possible stretches of road were <br />discussed. It is my understanding that the loop leading to and from <br />the coal hopper was not considered a road at that time, because it <br />was understood that trucks would be driving without a defined path <br />on the emergency coal storage pad. <br />Exhibit 12-2, as well as air photography of the site, show the <br />following well defined roadways (see enclosed map): <br />1. The proposed haul road from the tie-across haul road to <br />the proposed truck loadout. <br />2. A loop running from tie-across haul road to the truck <br />dump hopper and back to the tie-across haul road. <br />3. A roadway leading from the proposed truck loadout to the <br />truck dump hopper area. <br />Exhibit 12-2 also shows ditches on both sides of the later two <br />roadways. <br />Please justify why these later two possible roadways should not be <br />considered ae roads or submit information to the permit application <br />necessary to designate the later two roadways as either haul roads <br />or access roads. Please be aware that there are some allowances in <br />the regulations for alternative specifications, as well as, the fact <br />that the ditch inside of the truck dump loop might be eliminated <br />without, perhaps, affecting the performance of the truck loop pond. <br />