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-. ~~ I~~ I~~ I II~ I~I Ems. JUL 101981 AAIMtD LAI~ID IiECLAAAATIOM DIVISIOW In Reply Refer to: 4480 INE United States Department of the Interior OFFICE OF SURFACE MINING RECLAMATION AND ENFORCEMENT SUITE 310 6?5 SILVER AVENUE, S.W. ALBUQUERQUE, NEW ICO 87102 Jut. o B ~ Mr. Fred Banta, Coal Program Supervisor Mined Land Reclamation Division Department of Natural Resources 423 Centennial Building 1313 Sherman Street ___ __ _ " -'Denver, CO -80203 - Re: TDN No. 87-02-006-003, Twin Pines Coal Company, Twin Pines No. 2 Mine Dear Mr. Banta: The Albuquerque Field Office, Office of Surface Mining Reclamation and Enforcement (OSMRE), has reviewed the Colorado Mined Land Reclamation Division's response to Ten-Day Notice No. 87-02-006-003. The Division's response to violation No. 1's culvert-sizing problem is inappropriate. If the operator has installed two 18-inch culverts rather than one 24-inch culvert and the Division's calculations prove this to be adequate, then the operator may, indeed, be in compliance with Section 4; however, Sections 5.03.2 (2) (a) and 5.01.3 (1) (d) imply that compliance with the approved permit is required and, because the operator's mine plan map specifies a 24-inch culvert to be placed, a violation still exists. If the change is acceptable, the permit should be revised accordingly. The Division's response to violation No. 2's culvert- plugging problem is also inappropriate. First, the accumulation of sediment in a culvert may be corrected with maintenance, but the violation of Section 4.03.2 (4) (e) (iii) is a construction issue. The operator is responsible for installing culverts properly so as to prevent the accumulation of sediment. Second, page 72 of the permit may indicate the access road should now be considered a county road, but it is not clear. Any written confirmation from