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iii iiiiiiiiiiiu iii <br />STATE OF COLG~.~ ~~~ <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1313 Sherman 51.. Room 215 <br />Denver, CO 80203 <br />Phone: 13031 866-3567 <br />FAX: (303) 832.8106 <br />January 29, 1993 <br />OF'~~1~ <br />Nc6 ~*~ <br />•,~~~,• <br />Roy Romer <br />Governor <br />michael 8 long <br />Division Director <br />Mr. Robert Hagen <br />Office of Surface Mining <br />Albuquerque Field Office <br />505 Marquette NW, Suite 1200 <br />Albuquerque, NM 87102 <br />RE: TDN X-92-02-270-003 (TV-2); Roadside/Cameo Mine (C-81-041) <br />Dear Mr. Hagen: <br />This letter will resolve issue 2 of 2 in the above referenced TDN <br />issued at the Roadside/Cameo Mine. The TDN was written for failure <br />to contemporaneously reclaim portions of refuse piles CRDA 1 and 2. <br />The Colorado Division of Minerals and Geology (DMG) is issuing <br />Notice of Violation C-93-004 to Powderhorn Coal Company for failure <br />to contemporaneously reclaim the lower lifts of the refuse piles. <br />Abatement of the NOV entails completion of the ongoing cover study <br />field trials and outlines a schedule for submittal of study <br />results, a determination by DMG of the minimum required cover depth <br />and, construction dates for reclamation of the lower portions of <br />the piles. DMG considers this an appropriate response to issue 2 <br />of the TDN. We have requested a review of AFO's response to our <br />answer to issue one of the TDN by the Deputy Director in a separate <br />letter. <br />While issue 2 of the TDN should be resolved by this enforcement <br />action, DMG would like to clarify and respond to four points that <br />were made in AFO's January 15, 1993 resppponse letter. These four <br />issues are discusssed below. <br />1. Paragraph 2, page 3 of AFO's letter states, "... DMG agrees <br />with the position that reclamation of the pile be concurrent with <br />construction (page 2, paragraph 5)." AFO's letter ignores the next <br />sentence in DMG's response begins with, "However, due to...". <br />AFO's letter reflects only a portion of DMG's position on the <br />question of what is contemporaneous in this case. DMG's still <br />maintains that the ongoing field trials should be completed before <br />reclamation of the piles begins <br />