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iii iiiiiiiiiiiu iii 999 David From: Mathews, Dan Sent: Wednesday, July 25, 2001 5:20 PM To: Berry, David Subject: Powderhorn Monthly Report I have a few comments regarding the July monthly report which you faxed to me today. The discussion under Reclamation on the front page of the memo is in line with the permit reclamation schedule (in fact if CRDA-2 reclamation is completed by the end of 2001 it would be ahead of schedule). I verified that CRDA-2 grading and wash plant demolition had been initiated on my inspection last week. On page 2 of the memo, the first sentence of Paragraph 2, which states that regrading of the Cameo Refuse Pile will be partially completed by late Fall 2001, is a bit unclear, since there are two "Cameo Refuse Piles" (CRDA-1 and CRDA-2). assume the reference is to CRDA-1, since on the previous page it is stated that CRDA-2 would be fully completed by the Fall of 2001. The approved reclamation schedule calls for both CRDA-1 and CRDA-2 regrading to be completed by the end of first quarter, 2002, and full reclamation of both piles to be completed by the end of 2002. The following sentence indicates that the partial regrading would include placement of demolition debris at the property. This is of concern because the approved reclamation plan does not allow for disposal of demolition debris in or on CRDA-1 or CRDA-2. There is reference to haulage of coal and refuse remaining in stockpiles to a refuse area for disposal, but this is not "demolition debris". In reviewing the applicable permit sections, I did note reference to disposal of demolition debris in the vicinity of the old Roadside Refuse Pile (RSRDA). On page 14-8, paragraph 1 states: Regrading of the lower parking area and the preparation plant will begin with clean-up of refuse and coal stockpiles. This material will be placed in the RSRDA. Concrete, asphalt and other non-toxic material remaining after demolition of the surface facillities will be dozed into the area to be backfilled along the east edge o(this site. We may need to have the operator clarify the specific location envisioned for debris disposal, and ensure that such debris will not be placed in the refuse pile itself. You mentioned that Powderhorn representatives had mentioned something about use of refuse material to achieve required grades or elevations. This most likely would be in the vicinity of the old refuse pile/south portal area I assume. We may need to get clarification that any refuse material would be contained within the perimeter of the 100 year diversion system depicted on Exhibit 6C, and that such material would be placed in compacted lifts in accordance with applicable refuse pile design and regulations. In the 4th paragraph on page 2, there is reference to deferred removal of the [South Portal] office complex pending determination of commercial interest in the facilities, and the statement that a minor revision would be submitted to address these issues. Retention of the offce facilities for future commercial use would entail a land use change, AOC variance, and other significant changes to the reclamation plan, and would probably need to be handled as a Permit Revision. I assume that the referenced minor revision would be limited to a request to amend the reclamation schedule until a determination of feasibility of commercial use has been completed. also have some concerns with the final sentence under the Reclamation section, on page 2. First, it states that CRDA-1 is scheduled for completion in 2004. As I mentioned previously, under the approved reclamation schedule, both CRDA-1 and CRDA-2 are to be fully completed by the end of 2002. Secondly, it states that remaining reclamation other than work addressed in the report will largely be structural demolition. This statement is questionable, primarily because of the significant amount of earthwork associated with reclamation of the North Portal facilities area and the unit train loadout. Let me know if you have questions, and how you would like to proceed regarding the issues which need to be clarified