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r K~ - STATE OF COLORADO DIVISION OF MINERALS AND GEOLOGY Depanmeni of Natural Resources 1313 Sherman Sl., Room ? 15 gL Denver, ColoraAo R0203 II y # Phone: 13031 866-3567 '. II ~ FA%:(3031832-8106 ~i DEPARTMEN'T' OF - June 4. 1998 NATURAL- RESOURCES~' Mr. Bill Balaz Roy Romer Powderhorn Coal Company Goverrwr lames S. Lochhead P.O. Box 1430 Executive Director Palisade Colorado 81526 Michael B. Long , Division Director 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 the 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 are required for all haulroads or access roads not within the "disturbed area", 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 13-2 of the permit application, it would appeaz 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 regazding 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