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~OWDERHORN <br />COAL COMPANY <br />September 23, 1991 <br />Mr. Larry P. Routten <br />Senior Reclamation Specialist <br />Colorado Mined Land Reclamation <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203-2273 <br />RE: N.O.V. C-91-020, File C-81-041 <br />Dear Mr. Routten: <br />999 <br />P.O. Box 1430 <br />Palisatle. Goloratlo 81526 <br />(3031464-7951 <br />Fax (3031464-7181 <br />'^ ~- <br />p >~~y~ ~\ <br />S` P 2 6 1991 <br />Mined Land <br />Reclamation, pi~ision <br />This letter is to provide further information on circumstances <br />surrounding N.O.V. C-91-020. Further investigation of perimeter <br />boundaries has been done. Apparently, most of the markers were <br />installed in early 1983 after the January 3, 1983, permit <br />approval. Jim Herron, in a May 1983 inspection report, noted <br />that "Perimeter markers have been place around the disturbed area <br />boundary." Up to now I have not heard of anyone questioning the <br />adequacy of these markers and as a result had not questioned them <br />myself. Subsequent to receiving the N.O.V. I have looked for <br />documentation on how or where the markers were installed and have <br />found none. The people who installed them are no longer around. <br />I have walked the over 8 miles of disturbed area boundaries and <br />concluded that steel fence posts were placed at permit boundary <br />corners or turning points. The distance between the markers <br />ranged from 100' to 1700'. Most of these markers were still in <br />place but only locatable with a good topographic surface <br />disturbance area boundary map. The majority of those that could <br />not be found should have been at river's edge in very heavy <br />willow and tamarisk cover. It appears to me that the rational <br />for no more frequent placement of markers was primarily due to: <br />- barriers such as the Colorado River, the D&RG railroad <br />and highway fences, <br />- boundary lines a considerable distance beyond existing <br />and permitted disturbance, <br />- boundary lines beyond diversion ditches which are <br />commonly known as the maximum extent of disturbance. <br />