PERMFILE70340

• Permit No: C1982054
• IBM Index Class Name: Permit File
• Doc Date: 5/25/1990
• Doc Name: CARBON JUNCTION MINE PERMIT RENEWAL FN C-82-054
• From: MLRD
• To: DAVID R STURGES
• Media Type: D
• Archive: No

~ III ~II~I~~II~~II~II STAT~OF COLORADO~~
MINED LAND RECLAMATION DIVISION
• Department of Natural Resources
1313 Sherman 5;.. Rxm 215
Denver. CO 80203
3D3 8663567
Fax [phone]
May 25, 1990
Mr. David R. Sturges
Attorney-at-Law
P.0. Box 101
Glenwood Springs, CO 81602-0101
Re: Carbon Junction Mine Permit Renewal File No. C-82-054
Dear Mr. Sturges:
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Jim Stevens indicated that after the Board meeting you asked if we would
update you on the status of the Renewal Adequacy concerns for the Carbon
Junction Mine. I believe the issues which have been resolved to date are the
submittal of Annual Hydrologic Reports for 1986 through 1989, and submittal of
an updated probable hydrologic consequences evaluation (PHC) as specified in
Items 3 and 5 of the January 10, 1989 Adequacy Letter, and Condition C of the
• Letter of Agreement. The updated PHC discussion will need to be modified to
some extent and paginated for direct insertion into the permit document.
Some additional issues have arisen recently, other than the bonding issue of
which you are aware. By letter of March 13, 1990, we indicated a concern that
diversion and collection ditches associated with the excess overburden fill
had apparently not been designed to handle runoff from the 100-year, 24-hour
precipitation event. We stated in that letter that the 100-year, 24-hour
design criteria would apparently apply to Diversion Ditch #2, the East and
West Fill downdrains and the permanent channel realignment. Since the West
Collection Channel currently functions to divert the flow of Carbon Junction
drainage around the excess overburden fill, it too would need to meet 100-year
design criteria. A related concern is that an alternative plan is necessary
for handling road drainage which is currently routed over the face of the fill
into Sediment Pond No. 2. An appropriate plan for conveying drainage into the
pond via a designed ditch located off the fill will need to be submitted as a
part of the permit renewal response.
Jim Hendricks responded to the above concerns in a letter we received April 5,
1990, and contended that the referenced criteria did not apply because ditches
of concern were in-pit disturbances. I do not believe this to be the case and
we may need to schedule a meeting to discuss the issue further.
Correspondence applicable to this issue is enclosed.
Finally, I received a phone call yesterday from a Mr. Terry Oliver of the
• First Interstate Bank of Denver, Trustee of the Elizabeth Anne Ewing Trust,
the surface and mineral owner of the Carbon Junction Permit Area. Mr. Oliver
indicated that it was possible that the Pueblo Coal Inc. lease would be
terminated. Our records indicate that the lease expired in June, 1989.