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<br />• ~ III IIIIIIIIIIIIIIII <br />STATE OF COLUI~UU <br />DIVISION OF MINERALS AND GEOLOGY <br />Deparlmenl of N.llurul Resources <br />I }U Sherman SI ,Room Z1 S <br />Denver, Colorado 80203 <br />Phone: 17071 866-3567 <br />FAr (}03183'-81176 <br />August 13, 1997 <br />Ms. Christine Johnston <br />Mountain Coal Company <br />P.O. Box 591 <br />Somerset, CO 81434 <br />~~~ <br />DEPARTMEfYT OF <br />NATURAL <br />RESOURCES <br />Roy Romer <br />Goeernor <br />tames 5. lochhead <br />E~ecmive DireClor <br />M¢hael B Long <br />Division Director <br />Re: Adequacy Review; Minor Revision No. 219; West Elk Mine; Permit Pio. 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 ertor. 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 are 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 azea 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 151,000 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-11B. It would appear that Map 3E is cortect, and that the ertor is in the SEDCAD <br />run. Please review the map and model and clarify this apparent discrepancy. <br />The outcome of this issue affects the designs for CSLY-12, DSLY-13, CSLY-l3, and <br />CSLY-7, which may need to be revised. <br />