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STATE OF COLORADO <br />DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />November 5, 2010 <br />Mr. George Patterson <br />General Mine Manager <br />Kerr Coal Company <br />P.O. Box 459 <br />Florence, CO 81226 <br />Re: Marr Mine, Permit No. C-1980-006, Permit Renewal No. 6, Preliminary Adequacy Review <br />Dear Mr. Patterson: <br />COLORADO <br />D IV IS I ON OF <br />RECLAMATION <br />MINING <br />SAFETY <br />Bill Ritter, Jr. <br />Governor <br />Mike King <br />Executive Director <br />Loretta E. Pineda <br />Director <br />The Division of Reclamation, Mining and Safety (Division) has completed a review of the permit application package, inspection <br />reports, and other pertinent information as part of the renewal for Permit Number C-1980-006. The following issues have been <br />identified: <br />• Regarding the pond at the Loadout, Kerr Coal Company needs to reclaim the pond or clean the channel that potentially <br />receives discharges from the primary spillway. As noted in inspection reports, the channel for potential primary spillway <br />discharges contains a significant amount of grass, which obstructs observation of the spillway pipe below the <br />embankment. Cleaning the spillway is required by the permit and is necessary to effectively monitor pond discharges or <br />the lack thereof. <br />• The water quality monitoring locations and parameters are not clear. The text in the permit application package <br />(especially page 780-109a) and Table 61 should be updated to indicate that surface sites at the mine are no longer <br />monitored as well as any other updates to the monitoring methodology. Also, the Division's version of Map 36 does not <br />contain monitoring locations as indicated in the permit application package. <br />• In the permit renewal application form, the acres of released area (item number 13) do not appear to be accurate. The <br />Division calculates that these are the accurate areas: <br />0 60 percent released - 396.6 acres <br />0 85 percent released - 396.6 acres <br />0 100 percent released - 372.7 acres. <br />• In the Application Requirements of the application, the map references are not complete. For the items that require maps, <br />the map numbers are missing (e.g., Site Description and Land Use Information category). <br />• The Table of Contents in the permit application package does not reference Maps 23-1 and 37B. <br />A revised calculation shows that the bond held by the Division is insufficient for the remaining reclamation. The total cost for the <br />remaining reclamation activities for the Marr Mine permit is $19,827.00. This total results in $208.00 more that the estimate <br />conducted in January 2008 for SL4. This difference is explained by changes in equipment costs and a separate mobilization and <br />demobilization task for transporting equipment to the remaining acres at the mine site. A copy of the calculation is enclosed. <br />Please respond to these issues by the end of January 2011 to ensure a timely permit renewal. If you have any questions, please <br />contact me at 303.866.3567, extension 8113. <br />Sincerely, <br />Robert Zuber, P.E. <br />Environmental Protection Specialist <br />Enclosure: Reclamation Cost Estimate <br />Office of Office of <br />Mined I and Reclamation Denver Grand lunction Duraneo Active and Inactive Mines