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STATF. OF COLORADO DIVISION OF MINERALS 1N0 GEOLOGY DeOanmrnl nl .\~Nr.ll ReSOUrCei 1313 $hrrman $1., Room ? 1 j Denver. COIUfaCO tl0]pl Phony 13071 abb•}ib" Fa%: iip}1 713:.a10a November 8. 2000 ]im Stove- Powderhom Coal Company P.O. Box 143C Palisade, Colorado 8l C26 RE: Roadside Mine Reclamation Issues Permit No. C-1981-041 Dcar Mr. Stover. V ~ ~/, Dlal~ipa ~~11NEF: ~- GEOLO g E C t a n a' a~u o..,m, ( uri•nM Gr :. W.J<ne• i.r<uu.e Dnecmr M~<n.1ll B ~~Illl' prv O~pO p~rK¢n We appreciated the opportunity to meet with you, Mike Jamison and Tonya Hammond on October 30. At tlx meeting, Mr. ]amison stated that despite the bankruptcy, Powderhorn Coal Company (Powderttorn) intends to maintain compliance and conduct reclamation in azcordance with permtt and regulatory rcqu'vemenu at the Roadside North and South Portals Mine (Roadside). Mr. ]amison outlined a number of factors that contributed to the bankruptcy filing by Quaker Coal Company and iu subsidiaries, including Powderhom. You and Mr. Jamison also described various possibilities Powdcrhom is evaluative with respect to potential alternative land uses and reclamation modifications Cor certain affected areas and tacilities at Roadside. You indicated that Powderhom intends to submit an application for revision of the permit addressing these modifications and related reclamation scheduling cnanges. As we pointed out at the meeting, there arc three curtcrtly outstanding permiving actions that need to be brought to closure: Technical Revision No. 32, Technical Revision No. 3~, and the Mid-term Permit Review. Issues pertinent to these actions are outlined separately, below. Priority needs to be placed on providing substantivc, approvable plans in response to issues addressed in these actions, which have not yet bcen resolved. Resolution of these issues should be given priority over the possible land use changes and reclamation schedule changes you described at the meeting. You responded to the Division's August 10, 2000 TR-32 adequacy Icver in a submimal dated November 2, 2000. and we are curtently reviewing tha[ submittal. We request that substantive responses to previously issued adequacy levers far TR-33, and the mid-term review Ic¢tt be submined by no later than November ;0.2000. Failure to comply will result to enforcement by the Division. Technical Revision tTRI 32: Revision Order Mine Closure Reclamation Plan Changes TR-32 application was submined by Powderhorn on June S. 2000, in response to a February I8, 2000 revision order issued by the Division. The Division identified a number of deficiencies in the revision application, and issued an adequacy review lever on August 10, 2000, to which the operator has not yet responded. Two significant reclamation issues addresxd in the adequuy lever rela[e to hydrologic and geomorphic concerns with the final reclamation configure[ion of the CRDA•2 refuse area; and final reclamation plan for the Coal Creek channel permanent diversion, and the adjacent permanent road and associated culverts. The letter also requested additional detail regarding xdiment control demonstration (or the loadout area reclaimed [apography. During the review of TR-32, the Bureau of Land Management (BLM), as the land management agency, commented on the Coal Creek channel and road reclamation. Specifically, BLM requested that existing culverts along the road xgment of concern remain in place, with certain modifications to the "upper dip action" culvert concrete structure. and adjazent sections of the channel. _ E X H I B I T ! ~_