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Mr. Dan Hadley - 2 - April 23, 1987 <br />Chimney Rock has partially responded to these issues though the bond amount <br />and mass balance calculations were never completed. Preliminary evaluations <br />of existing topography and approved post-mining configurations have identified <br />areas of potential overfill in the former East Pit. A potential problem with <br />the mass balance was first brought to our attention in the autumn of 1986. <br />With the submittal of actual existing topography maps in December 1986, it is <br />apparent that in order to achieve the approved post-mining topography in the <br />Revision No. 1 area, material overfilled in the south portion of the former <br />East Pit area may need to be removed. Such a determination would <br />significantly affect the magnitude of the reclamation bond. This is the most <br />serious issue regarding the mine. <br />Several on-the-ground concerns need to be attended to on a regular basis at <br />this site. These are addressed in the following paragraphs. <br />Rills and gullies on the reclaimed surface at the former East Pit require <br />maintenance yearly. Revegetation success has been questioned by staff on <br />reclaimed areas of the former East Pit. Lack of effective cover has resulted <br />in rilling and gullying. Failure to manage rills and gullies and achieve <br />effective vegetative cover leads to geomorphic instability and water quality <br />problems due to excessive erosion. This situation needs to be monitored and <br />corrected. Ditch maintenance and haul road drainage maintenance are also <br />mandatory on a regular basis to maintain a functioning sediment control system. <br />Surface water monitoring requires monthly flow measurement at three sites and <br />quarterly analysis at those sites. NPDES reporting is also required and <br />sampling is required when discharge occurs. <br />Ground water monitoring requires depth to water measurements at seven wells <br />and quarterly analysis of each well. <br />Subsidence monitoring adjacent to the highway has been suspended. <br />Colorado Coal Mining Company <br />The Colorado Coal Mining Company's (GCMG) Mining Permit mid-term review was <br />conducted in December 1986. The issues raised during the Division mid-term <br />review have been resolved with the exception of the insertion into the permit <br />of a satisfactory reclamation cost estimate. The mid-term review showed that <br />the reclamation cost estimate used by CCMC was not satisfactory. As part of <br />the mid-term review response CCMC submitted revised reclamation cost <br />estimates. The Division reviewed this and determined that labor an machinery <br />costs used in CCMC's calculation were under estimated. The Division <br />calculated that reclamation on the current disturbance would be $287,174.00 <br />and CCMC had calculated $237,330.00. CCMC needs to submit a revised <br />acceptable estimate or accept the Division's calculations to insert into the <br />permit application. With the approval of the mid-term technical revision this <br />issue will be resolved. Currently the Division holds a bond of $348,401.18. <br />The bond is held as a $226,000.00 Corporate Surety and a $122,401.78 <br />certificate of deposit held with Western National Bank. <br />The CCMC Mine No. 1 has had 2 Notices of Violation (NOV) issued in the past <br />year. NOVs C-86-28 and C-86-29 were written for failure to seal and manage <br />exploration drill holes and wells. These have been resolved. The mine has <br />not had any other chronic problems identified that could become violations. <br />