_GENERAL DOCUMENTS - C1981017 ‎(287)‎

• Permit No: C1981017
• IBM Index Class Name: GENERAL DOCUMENTS
• Doc Name: Bid Documents ‎(IMP)‎
• Media Type: D
• Archive: No

5TATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources P IV 74,
1 313 Sherman St, Room 215
Denver,Colorado 80203
Phone [phone]
FAX:[phone]
DEPARTMENT OF
May 8, 1996 NATURAL
RESOURCES
Roy Romer
Governor
Richard Harlan James S
ad
Harlan and Associates Executive Director
3190 South Wadsworth Boulevard Michael B Long
Lakewood, Colorado Division Director
80227
RE: Coal Basin Work Plan
Dear Mr. Harlan:
The Division of Minerals and Geology has reviewed the Work Plan
prepared by Harlan and Associates for the Coal Basin property. We
would like to share with you our comments and questions, which
follow.
1. As a point of clarification, the Division and Mid-Continent
Resources (Resources) have not entered into an agreement, per se,
which outlines the scope of the parties responsibilities at the
Coal Basin Mine. Rather, a number of statutory requirements govern
the division of responsibilities at the site. The bankruptcy
liquidation plan outlines the responsibilities of Resources in
providing monies to various accounts, such as the reclamation fund
or the environmental fund. Expenditure of monies from any one fund
is also regulated by the liquidation plan. Minerals and Geology is
accomplishing reclamation of the site as required by the Colorado
Surface Coal Mining Reclamation Act. Funding is provided through
the liquidation of Resources estate. Resources remains responsible
for point source discharges via their National Pollutant Discharge
Elimination System (NPDES) permit, and is also responsible for
compliance with other applicable environmental statutes.
The liquidation plan requires that this audit, other studies and
any clean up activities which result from these investigations
shall be paid by funds other than those earmarked for reclamation
of the mine site, in that these activities are required by laws
other than the Colorado Surface Coal Mining Reclamation Act.
2. Section 1.2 states that additional investigations may be
proposed if environmental liabilities are identified during the
initial investigation. Please define the term 'environmental
liabilities' . Investigations beyond the initial site assessment
will be conducted based upon this criteria, and therefore, no
ambiguity in the term or criteria should exist.