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~~I ~I~~I~~I~~~~~~~~ STATE OF COLORADO DIVISION OF MINERALS AND GEOLOGY 1)vparlmcnl of N.lural Rcaourcc~ 141 t $hrnnan 51., Room 21 5 I k•nvcr, Culniadu tlll?oJ I'hunc: l {1111 H66-3567 FAt IIU II H3~P106 May 26, 1994 Mr. Mitchell Rollings Office of Surface Mining 505 Marquette NW, Suite 1200 Albuquerque, NM 87102 I~~~~ DEPA RI MEN-f (~ NATU RAI RESOURCE: kuc kunu+ c~.~r~,~„~~ Krvn ti.il.v,n Ea mi~!• ITir~ i~~~ her h,u •1 R L,n is RE: Reclamation of the Refuse Piles at the Roadside/Cameo Mi~i~"'°I''"'~"' Dear Mr. Rollings: This letter is in response to your request for clarification of the position taken by the Division of Minerals and Geology (DMG) in regard to the reclamation of Cameo Refuse Disposal Areas (CRDA) 1 and 2 by Peabody Western Coal Company following issuance of Colorado NOV C-93-004. A summary of the plans in the Roadside permit and the course of events in which DMG and PWC were involved is presented below. At the time DMG issued an NOV regarding reclamation of the piles, the Roadside permit included plans for the existing Roadside refuse pile, CRDA 1, CRDA 2, and the proposed CRDA 3. Those plans included engineering designs for the piles and associated sediment control structures. Reclamation cost estimates were also made for covering CRDA 1 and 2 with the required four feet of cover. Those estimates assumed the required volumes of material would be available from a borrow area located within 3500 feet of the piles. However, the borrow areas were not identified or permitted at the time. OSM has questioned why cover material made immediately available from the simply posting the required bond for CRDA 3 for this purpose would result all three refuse piles, assuming foul A summary of pertinent volumes is: for CRDA proposed CRDA 3. in a def feet of 1 and 2 could not be CRDA 3 location by Using material from icit of material for cover was required. 335,700 LCY needed to cover CRDA 1 and 2 -48,300 LCY available from CRDA 1 and 2 excavation 287,400 LCY deficit for CRDA 1 and 2 -90,000 LCY available from CRDA 3 197,400 LCY deficit for CRDA 1,2, and 3 These volumes are based on approved salvage and reclamation plans in the permit at the time the NOV was issued.