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J C~ J Richartl D Lamm Governor • ~II II~I~~i~~ll~~ I~~ DEPARTMENT OF NATURAL RESOURCES Davitl H. Getches, Executive Director MINED LAND RECLAMATION DIVISION DAVID C. SHELTO N, Director December 6, 1985 Mr. Clem Parkin Director of Environmental Affairs New Castle Energy Corporation 9137 East Mineral Circle Englewood, Colorado 80112 Re: Technical Revision No. 2 - Portal Deck Expansion, Coal Ridge No. 1 Mine, File No. C-84-065 Dear Mr. Parkin: Enclosed is a memo from Jim Pendleton which addresses stability concerns pursuant to the above referenced Technical Revision. Our recent telephone conversations indicate that New Castle Energy (NCE) is planning to modify the deck expansions to be temporary fills as a means to satisfy the stability criteria within the existing plan. This modification should be submitted to the Division in writing. The only other outstanding adequacy issue concerns a statement that some topsoil in the disturbed area may not be salvaged due to access problems. The Division strongly recommends that NCE commit in writing to the salvage of all topsoil in the disturbed area to the required depth. However, if NCE wishes to request a variance from topsoil salvage, the following information must be submitted to the Division for review: 1) Justification that the reason for the request is valid (steep slopes, rocky outcrops, thin soils etc.); 2) Describe what types of alternative mitigative measures will be taken or will be needed to ensure vegetation will be established; 3) Submit a map which clearly outlines the area for which the exemption is requested (make sure the map correlates with the baseline soils map); 4) Submit a demonstration that the substitute topsoil is as suitable as the existing soils; 5) Submit geochemical (quality) information on overburden that may have a thinner cover of topsoil placed on it due to the exemption; 423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203 Tel. (303) 866-3567