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iii iiiiiiiiiiiiiiii 999 STATE OF COLORADO DIVISION OF MINERALS AND GEOLOGY Depanmenl of Natural Resources 1713 Sherman St., Room 215 Denver, Colorado 80207 Phone: (303) 866-3567 FAX 1307) 832-8106 December 7, 1994 Mr. Larry Reschke Powderhorn Coal Company P.O. Box 1430 Palisade, CO 81526 RE: Roadside Portal Mines (C-81-041) MR-25; Rill & Gully Plan Dear Mr. Reschke, I~~~~ DEPARTMEM" OF NATURAL RESOURCES Roy Romer Governor lames 5. Lochhead E.ecmive Director Michael B. LOng Division Director The Division of Minerals and Geology received your minor revision application to include a rill and gully monitoring plan at the Roadside Portal Mines (C-81-041). The revision was received on December 1, 1994 and was deemed complete on December 6, 1994. The Division has a few concerns that should be addressed prior to approval of the revision. 1. Powderhorn states on page 192b that "areas where excessive erosion are observed will be evaluated to determine the cause." The principal behind a rill and gully plan is to maintain any rills or gullies before they become excessive. As stated in Section 4.14.6, rills and gullies should be maintained when such rills and gullies disrupt the approved postmining land use, prohibit successful revegetation or cause or contribute to a violation of water quality standards for a receiving stream. Please revise page 192b to include maintenance of rills and gullies rather than evaluate and maintain excessive rills and gullies. 2. Powderhorn has included channels and ditches in the rill and gully plan on page 192b. Rule 4.14.6 addresses rills and gullies in areas that have been regraded and topsoiled. Rule 4.05.3(1) addresses the compliance issues associated with channels and ditches. This rule states that channels and ditches "...must be designed, located, constructed and maintained and used to minimize adverse impacts to the hydrologic balance, and to be stable..."