_GENERAL DOCUMENTS - C1981017 (286)

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p1T OF TAKES PRIDE INS y o United States Department of the Interior AMEKA� OFFICE OF SURFACE MINING ®�_ % �4gCH e°9 Reclamation and Enforcement IN REPLY REFER TO: Suite 1200 505 Marquette Avenue N.W. Albuquerque,New Mexico 87102 April 26, 1994 !7 I") Mr. Michael B. Long, Director Division of Minerals and Geology Department of Natural Resources 215 Centennial Building 1313 Sherman Street ("`'y0y Denver, Colorado 80203 Re: Mid-Continent Resources Coal Basin Mine (Permit C-81-017) Dear Mr. Long: The Office of Surface Mining Reclamation and Enforcement (OSM) has reviewed your letter of March 15, 1994, and found that several aspects of this letter are of concern. I do not agree or consider that the ultimate reclamation plan will most closely align to the requirements of Title IV rather than Title V. My understanding is that the reclamation plan is being revised with respect to the roads within the permit area in accordance with the requirements of the post mining land use envisioned by the U. S. Forest Service. This is being developed by your staff but still should fall within the basic requirements-of Title V. -The requirements of Title V cannot be compromised except for items that would be required under a bond release situation, such as ponds remaining in place for a minimum of 2 years after seeding, the 10-year liability period, and the revegetation standards requirements. These are very limited performance standards which are being waived. In a meeting between your staff and OSM, it was agreed that Colorado would include numerous items that were not in the original reclamation plan and that needed to be done; some of these items are required and some were needed to ensure hydrological stability. Because these items were in addition to those in the $3 million reclamation plan, the cost of reclamation should be more than the $3 million referenced in your letter. OSM has essentially two Inspectable Units Lists. OSM Directive INE-20 establishes policy and procedures for selecting and implementing OSM's standard oversight sample inspection program in primacy States and defines standard oversight inspectable units as those inspectable units for generating the random sample inspection list. Standard oversight inspectable units are those on the Inspectable Units List except (1) coal exploration operations; (2) sites where final bond release has been granted; (3) abandoned sites or sites officially in any stage of the bond forfeiture process; and (4) unpermitted sites.