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<br /> <br /> iii iiiiiiiiiiiii iii <br />999 <br /> STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />~c <br />Department o(Natural Resources ~~oe <br />o~ <br /> ~ <br />~~:i <br />1313 Sherman 51., Room 215 <br />• <br />Denver, CO 80203 • <br />• • <br />' <br />Phone: (303) 866-3567 rave <br />FA%:13031832-8106 <br /> Roy ROmer <br /> Governor <br /> Michael B. Long <br /> Division D~reaor <br />September 16, 1993 <br />David L.. Beverlin <br />Edna Strip Mine <br />Pittsburg & Midway Coal Mining Company <br />P.O. Box 176 <br />Oak Creek, Colorado 80467 <br />RE: Edna Strip Mine (C-80-001) <br />Technical Revision 24 <br />Dear Mr. Beverlin: <br />The Division has received P&M's responses to our adequacy concerns pertaining to the above <br />mentioned revision. Following are our concerns with the submittal. <br />1. Page 3.5-Sh of the submittal states that ditches on the Goat Trail will be maintained <br />with a grader as scheduling permits. Rules 4.03.2(1)(a) and 4.03.2(6) require that roads <br />and ditches be maintained as designed at all times. The Division cannot approve a <br />variance from those requirements due to equipment scheduling. Please remove the <br />maintenance exception statement from the text: <br />2. Page 3.5-h of the revised text states that portions of the Goat Trail are not conducive <br />to ditch construction since the road is cut into bedrock. The text further explains that <br />the road will be sloped toward the hill. Field observations of one such area showed that <br />water tended to impound where the road sloped into the hillside. Please provide the <br />Division with locations of all areas where ditches will and will not be constructed, and <br />a detailed demonstration that positive drainage will be achieved, as required by Rules <br />4.03.2(1), 4.03.2(4)(c), and 4.03.2(4)(d). <br />3. Revised page 3.5-Sk includes statements that haul roads will be maintained daily whe^ <br />a particular road is in use, and that access roads will be maintained periodically when <br />scheduling permits. As stated above, the roads must be maintained as designed at all <br />times. <br />4. Page 3.6-3 of the revised text states that the Goat Trail cannot be brought into <br />compliance with current performance standards due to its pre-SMCRA construction. <br />