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x <br />t-` <br />STATE OF CC ~~~ ~~~~~~~I~~~~~ ~I~ <br />MINED LAND RECLAMATION DIVISION <br />Department of Natural Fesources <br />'.313 Sherman St Foom 215 <br />Denver. CO 80203 <br />303 856 356' <br />FAX 303 832 8106 <br />DATE: January 17, 1990 <br />T0: Jefferson Clayton n <br />FR0~1: Carl Mount~~,~.~/`V~' <br />of co~~ <br />~ti' k <br />,e/ %.~/ <br />. ~ O <br />.\'.; <br />~ /a 76 ~ <br />RoY R¢me~ <br />Govemo~ <br />Red R. Banta <br />Division D ie^ror <br />RE: Adequacy Review - Soils and Stream Buffer Zones, Permit Revision <br />Number One (PR-Ol), Pittsburg and tdidway Coal Company's (P&t1) <br />Edna tdine, Permit C-80-001 <br />I have completed the adequacy review of PR-O1 for soils and stream buffer <br />zones and have the following concerns: <br />1. P&M has submitted a detailed soil removal plan description included in <br />Section 4.3 of the Permit Application Package (PAP). Table 4.3-2 (pane <br />4.3-5) was checked against Exhibit 4.3-1 - Topsoil Mass Balance and found <br />to be in close agreement. This part of the PR was adeouate. <br />2. P&M has eliminated topsoil replacement details from Exhibit 4.4-1, Sheet <br />1 of 1 - Conceptionalized [sic] Reveaetation. Elimination of these <br />designations makes the proposed PR topsoil handling plan out of <br />compliance with Rule 2.05.4(2) which requires, among other things, <br />detailed timetables and plans for ..redistribution of topsoil, subsoil, <br />and other material to meet the requirements of 4.06." P&M should submit <br />a map that is similar to the presently approved Exhibit 4.4-1, Sheet 1 of <br />1 so the proposed plan meets the requirements of Rule 2.05.4(2)(a) <br />and (d). <br />3. Page 4.3-6 has a statement that references a road that will be left <br />through the reclaimed t+loffat Area to allow management of the area. Will <br />this road eventually be reclaimed? <br />4. Page 4.3-9 states that "At the end of year 9 the southern stockpile will <br />become inactive." If this is indeed true, why do "South Stockpile Cu. <br />Yds." constantly get larger after year 9? <br />5. Will the area under the footprint of the south topsoil stockpile be <br />topsoiled to some thickness subsequent to use? <br />6. Exhibit 4.3-1 - Topsoil Removal Years Related to Mining Years elicited <br />concerns as follows: <br />a. Where will the topsoil stockpiles be accessed from? The map does <br />not show the location of stockpile access roads. <br />