GENERAL36949

• Permit No: C1981041
• IBM Index Class Name: General Documents
• Doc Date: 6/4/1998
• Doc Name: STIPULATION 18 ROAD CERTIFICATES Letter
• From: DMG
• To: POWDERHORN COAL CO
• Permit Index Doc Type: GENERAL CORRESPONDENCE
• Media Type: D
• Archive: No

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999
STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Depanmenl of Natural Resources
1313 Sherman Sl., Room 215

Denver, Colorado 80207 I~~~~~
Phone: [phone]
FAX. [phone]
DEPARTMEIJT OF
NATURAL
June 4
1998
. RESOURCES
Mr. Bill Balaz Roy Romer
Governor
Powderhom Coal Company lames 5. Lochhead
P.O. Box 1430 Executive Director
Palisade Colorado 81526 Michael 8. Long
Division DireUOr
RE: Roadside Mine, Permit No. C-81-041
Stipulation No. 18; Road Certifications
Deaz Mr. Balaz:
As you know, the Stipulation 18 deadline for submittal of updated road certifications or
statements in lieu of certification, is June 24, 1998. You had requested some guidance to assist
you in preparing the required statements. Currently, only three of the roads at [he mine have
been certified (Haulroads 1, 2, and 3). Permit road designations and DMG regulations pertaining
to certification of haulroads and access roads have both been altered substantially since the three
haulroads were originally certified, necessitating the requirement for updated statements.
Because all of the roads in question were constructed or reconstructed prior to August 1, 1995,
relevant showing statements may be submitted in lieu of certification, pursuant to Rules
4.03.1(1)(d)(ii), and 4.03.2(1)(f)(ii). Such statements aze required for all haulroads or access
roads not within the "disturbed azea", as defined in Rule 4.05.2(4). In general, a statement in lieu
of certification is required for any road segment for which surface drainage is not routed through
a sediment pond or treatment facility designed to ensure that the road drainage meets CDPS
discharge standards, Based on Table ] 3-2 of the permit application, it would appear that
certification or statement in lieu of certification would be required for portions of Haul Roads 2,
3, 4, 5, and 6, and portions of Access Roads 2 and 3.
Relevant showing statements do not need to address construction specifications, for which
records may not exist, but do need to document compliance with performance standards which
can be observed and measured in the field. The statements should address compliance with
regulations and permit specifications regarding location; horizontal alignment and maximum
grade requirements; width requirements; cut slope and embankment slope gradient requirements
(or applicable safety factor if grades exceed regulatory specifications); drainage requirements
including erosion control, ditch, culvert and bridge specifications; surfacing; and maintenance.
Road segments which do not comply with specifications of 4.03.1(3) or 4,03.2(3) addressed
above (if they occur), would need to be identified in the statement, and demonstrations of