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III IIIIIIIIIIIIIIII <br />DIVISION OF MINERALS AND GEOLOGY <br />Depa rlmem of Natural Resources <br />131 3 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone. 1303) 866-3567 <br />FAX:(303)832-8106 <br />August 8, 1996 <br />Mr. John Walters <br />Grand Valley Coal Company <br />P.O. Box 70 <br />Loma, Colorado 81524 <br />I~~~~ <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br />Roy Romer <br />Governor <br />lames 5. Lochhead <br />6ecmive Dueaor <br />Michael B. Long <br />RE: Road Statements of Compliance Davison Diredo~ <br />McClane and Munger Mines, File C-80-004 and C-81-020 <br />Dear Mr. Walters: <br />It recently came to my attention that the certifications for the <br />existing haul roads at Munger and McClane Canyon Mines have not <br />been updated since the rule changes pertaining to roads became <br />effective earlier this year. Given the pre-existing status of the <br />roads, they are in essence "grandfathered" from the design <br />requirements of the amended rules, and a new P.E. certification <br />will not be required. However, a "relevant showing" pursuant to <br />Rule 4.03.1(1)(d)(ii), indicating that the roads meet the <br />performance standards of Rule 4.03.1, will be required for each <br />operation. <br />The statements should address each performance standard of 4.03.1, <br />and may be based on either analytical data or empirical <br />observations. Due to inherent impracticalities, analytical <br />documentation of embankment placement, materials, and compaction <br />levels attained is not required, and the assessment of stability <br />can be based on current appearance, present and historical use and <br />performance, the need for repairs other than routine maintenance, <br />and the current and historical functioning of the drainage control <br />system. <br />Please submit the relevant showing statements at your earliest <br />convenience. Give me a call if you have any questions. <br />sincer ~~ <br />Dan Mathew's <br />Environmental Protection Specialist <br />STATE OF COLORADO <br />cc: Larry Routten, DMG Denver <br />