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~. <br />DIVISION OF MINERALS AND GEOLOGY <br />Depanmenl of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80201 <br />Phone: 1303) 866-3567 <br />FAX: 13071 832-8106 <br />December 21, 1995 <br />III IIIIIIIIIIIIIIII <br />STATE OF COLORADO <br />~~~ <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br />Mr. Brian D. Gontarek "°° R°""" <br />Environmental En ineer e~~.e,"n, <br />lames S lochhead <br />The Pittsburg & 'dway Coal Mining Company e.e~",,.e D„e~,"r <br />P.O. Box 6518 m;~naei a. ~nnX <br />Englewood, Colorado 80155-6518 0~~~„"" o~,ec~"~ <br />RE: Edna Strip Mine (C-80-001) <br />Technical Revision 34 <br />Moffat Area Postmining Topography <br />Dear Mr. Gontarek: <br />The Division has reviewed materials submitted in support of Technical Revision No. 34 to the <br />Edna Mine permit. As a result of that review, we have the following questions and comments. <br />1. As depicted on Exhibit 3.4-4, in some areas Unnamed Drainages #1, #2, and #3 run <br />parallel to the slope. There are a number of areas where the drainages make abrupt <br />changes from perpendicular to the slope to parallel. This drainage configuration does <br />not represent appproximate original contour. The premining topograpphy was characterized <br />by shallow, slightl meandering drainages running down the slope. It is also not apparent <br />how permanent drainages which are constructed across slope vnll be stable, as required <br />by Rule 4.05.3(1)(e). Please revise the plan so that the reclaimed area will be returned <br />to approximate original contour, with respect to the drainage density and characteristics, <br />as required by Rule 4.14.1(2)(a). <br />2. We are unable to locate designs for Unnamed Drainages #1, #2, and #3. When I <br />telephoned you (December 15, 1995) regarding these designs, you informed me that no <br />designs had been generated, since they are just low areas in the topography and not large <br />drainages. Since these features were reconstructed on the reclazmed land, and will <br />convey water, the Division has determined that they are indeed drainages, and as such <br />are subject to Rule 4.05.3 which addresses diversions and ephemeral channel <br />reconstruction. Accordingly, designs must be submitted to and approved by the Division. <br />Please provide designs for these drainages. <br />3. The currently approved permit application includes a demonstration that approximate <br />original contour can be achieved at final reclamation without using the material from the <br />initial boxcut; that the boxcut material was excess spoil. This demonstration was based <br />on mining to the end of the Moffat area reserve. Stnce mining ceased prior to reaching <br />the end of the reserve, in accordance with Rule 4.14.1(2)(d), this demonstration should <br />be revised. Please update the demonstration to indicate that at this point in the pit <br />progression, the initial box cut material is excess spoil since it is not required to achieve <br />approximate original contour at final reclamation. <br />4. P&M is proposing permanent retention of the North and South Collection ditches. In <br />order for the Division to approve retention, P&M must demonstrate compliance with <br />Rule 4.05.3. As we discussed on the telephone, the Division has one concern in <br />particular with the grade on the South Collection Ditch. Our observations since its <br />