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~ -_ <br />~II II~~I~II~~~~~ II~ <br />999 <br />STATE OF COLORADO <br />Roy Romer, Govei <br />DEPARTMENT OF NATURAL RESOURCES <br />MINED LAND RECLAMATION DIVISION <br />FRED R. BANTA, Dlreetor <br />November 16, 1989 <br />Mr. David Gossett <br />Kerr Coal Company <br />c/o ACZ Engineering <br />1475 Pine Grove Road <br />P.O. Box 774018 <br />Steamboat Springs, CO 80477 <br />Re: Preliminary Adequacy Review, Permit Revision No. 1 <br />Marr Mine, C-80-006 <br />Dear Mr. Gossett: <br />The Division has prepared a preliminary set of adequacy questions on Permit <br />Revision No. 1. We would like to commend you and your staff for reorganizing <br />the permit to reflect the format of the Regulations of the Colorado Mined Land <br />Reclamation Board for Coal Mining and for updating the permit. The three ring <br />binders area real improvement aver the screw and post binders. <br />I would like to take this opportunity to review the major issues covered by <br />this letter, to afford you a framework for planning your response development. <br />The proposed backfilling reclamation plan needs revision to meet the <br />criteria of approximate original contour found in the definitions <br />(Rule 1.04(13)). The staff prepared perspective maps to assess <br />comparability between the pre-mining topography and the post-mining <br />topography, and these are enclosed for your perusal. <br />The Division is unable to consider a request to construct excess <br />overburden piles until a backfilling and grading plan which meets AOC <br />is proposed and mass balance calculations are prepared which document <br />surplus material. <br />The Division believes that there are sodic zones in the overburden based <br />on information found in the approved permit application. Kerr chose to <br />re-interpret the quality of this material through averaging geochemical <br />data from all zones and by claiming that some holes were contaminated <br />with sodium-based drilling fluids. The Division asks that this data be <br />analyzed in a scientific manner as detailed later in this letter. <br />215 Centennial Building, 1313 Sherman Street Denver, Colorado 80203-2273 Tel. (303) 866-3567 <br />