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III IIIIIIIIIiIII III <br />999 <br />United States Department of the Interior ~~ <br />OFFICE OF SURFACE MINING <br />RECLAMATION AND ENFORCEMENT ~~ ~ <br />SUITE 310 <br />625 SILVER AVENUE, S.W. („ Reple Rr(r, To: <br />ALBUQUERQUE, NEW MEXICO 87102 <br />October 9. 1991 <br />.-. ,~ <br />~,,. dU~I_~~ <br />;,'ti1991 <br />,,r,~'d Land <br />'~;,,IaiIOR ~IVI$IOIj <br />Re: Can dian Strip Proposed Phase II Bond Release <br />Dear Mr. Bucknam: <br />Mr. David L. Bucknam, Acting Director <br />Mined Land Reclamation Division <br />Department of Natural Resources <br />215 Centennial Building <br />1313 Sherman Street <br />Denver, CO 80203 <br />.\\~ <br />The Albuquerque Field Office's (AFO) previous letter (dated 8/30/91) to <br />you on the subject of this proposed bond release requested that your <br />office provide a copy of the demonstration made to support the proposed <br />retention of permanent impoundments under Colorado Rule 4.05.9(1)(b). <br />AFO has evaluated your reply (dated 9/12/91) which contained a copy of <br />Wyoming Fuel's adequacy response for Technical Revision TR-O6 (retention <br />of Ponds 1 and 2 as permanent impoundments) which MLRD approved on <br />8/1/91. The operator's adequacy response included a compilation of <br />quotes or paraphrased information from MLRD inspection reports between <br />8/14/86 and 6/10/91 as "qualitative historical documentation that the <br />ponds do retain a pool of water." <br />AFO does not consider this compilation of inspection report information <br />to be adequate documentation under Rule 4,05.9(1)(b), that the level of <br />water in the ponds is sufficiently stable to support the intended use. <br />The inspection report information from the operator indicates that, at <br />various times, one or both ponds were dry or contained amounts of water <br />which varied from "small amounts" to discharge levels. On the basis of <br />this information submitted by the operator as the demonstration that the <br />ponds may be retained as permanent structures, AFO cannot concur with <br />the proposed release of Pond No. 2 on public lands administered by the <br />Bureau of Land Management (BLM) or the designation of the ponds as <br />permanent impoundments under Rule 4.05.9(1)(b). <br />AFO has also noted that, in your 9/25/91 letter to this office, Wyoming <br />Fuels intends to challenge MLRD's guidelines requiring vegetative cover <br />for a Phase II release to be 90 percent of the reference area with 90 <br />percent statistical accuracy during the Mined Land Reclamation Board's <br />