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,; <br />DIVISION OF MINERALS AND GEOLOGY <br />Depdrlmpnl of Nuiurdi Resources <br />111 3 Sherman SL. Room ? I S <br />Dcrn~er. Colorado 8U'_03 <br />Phone: l}U71 H64.7567 <br />FAX: I SU71 87'~NI Ufi <br />August 13, 1997 <br />Ms. Christine Johnston <br />Mountain Coal Company <br />P.O. Box 591 <br />Somerset, CO 81434 <br />~~~~~ <br />DEPARTtv1ENT OF <br />NATURAL <br />RESOURCES <br />Roy Romer <br />Gae•nor <br />lames S. Lochhead <br />E.ecwrve Director <br />Michael B. Long <br />D~~isian DireOOr <br />Re: Adequacy Review; blinor Revision No. 219; West Elk Mine; Permit No. C-80-007 <br />The Division has the following remaining comments concerning the adequacy of MCC's <br />responses, regarding Minor Revision No. 219. <br />DMG's reference to Section 4.12.1 was a typographical error. The reference should have <br />been Section 4.14.1. MCC notes that the return of all spoil material is not necessary to <br />meet the requirements of approximate original contour. DMG agrees with the <br />demonstration provided, but will require that the demonstration be incorporated into the <br />permit application package. In addition to the demonstration that there aze 11,000 CY of <br />excess material, MCC needs to address the requirements of Sections 4.05, 4.06, 4.09, and <br />4.15. Specifically, MCC needs to specify the final location of the excess 11,000 CY of <br />spoil material, and demonstrate that the material will be stable; the fill will minimize <br />disturbance to the prevailing hydrologic balance; topsoil in the proposed location will be <br />salvaged, stored and replaced as required; and disturbed azeas will be revegetated <br />appropriately. In addition, MCC needs to demonstrate that the designated fill area can be <br />returned to approximate original contour with the addition of the excess spoil. <br />2. The Division has verified MCC's estimate of l ~ I,000 CY to be excavated. <br />3/4. MCC addressed the Division's previous concerns with the routing of runoff at the shaft <br />site. The information provided by MCC, however, presented a new inconsistency. The <br />diagram on Map 3E shows that drainage from the bench will flow to DSLY-18 and then <br />through CSLY-12. The accompanying SEDCAD runs show the bench draining to <br />CSLY-11 B. It would appear that Map 3E is correct, and that the error is in the SEDCAD <br />run. Please review the map and model and clarify this apparent discrepancy. <br />iii iiiiiiiiniii iii <br />STATE OF COLvi~nvv <br />The outcome of this issue affects the designs for CSLY-12, DSLY-13, CSLY-i3, and <br />CSLY-7, which may need to be revised. <br />