1986-11-28_GENERAL DOCUMENTS - C1981017

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DIID-CONTINENT RESOURCES. INC. lip 201 Centennial St..Suite 406 Glenwood Springs. Colorado 81601 OW)945-4958 August 4 , 1986 RECEIVED Ms. Candace Thompson AUG 7 1%6 Mined Land Reclamation Division 423 Centennial Building MINED LAND 1313 Sherman Street RECLAMATION DIVISION Denver, CO 80203 Dear Candace: This letter is in answer to the questions that came up during my July 9th meeting with you and Jeff Deckler concerning reclamation cost calculations. Consideration is being given to Jeff' s memorandum of July 14 on these same questions. Verification of Disturbed Acreage We do not include the mine bench outslopes in our disturbed area calculations because Mid-Continent believes that they should be grandfathered. They were developed long before SMCRA and have not been utilized in the mining operations since the Federal and State rules implementing the SMCRA requirements were promulgated. A review of the first 22 pages of Chapter V, Reclamation, in Volume 7 of the permit application does not address the reclamation of the mine bench outslopes. This reclamation plan was approved by both MLRD and OSM in 1983. See page 48 of the August 1984 MLRD Findings Document. Despite the Mid-Continent grandfathering claim, the company agreed with MLRD (Bowman and Herron) to establish revegetation test plots on several of the mine bench outslopes and monitor them over a ten year period. See Volume 6, Section H, page 13 and Volume 7, Appendix V-G-1 for the ten year examination. In summary, Mid-Continent does not believe that it should be required to revegetate grandfathered areas and, accordingly, does not include the mine bench outslopes in the calculation of total disturbed area. Backfilling and Grading - AOC Requirements The major issue with respect to the backfilling and gradi#ig portion of the reclamation plan for Coal Basin is the AOC question. With a variance granted based on steep slope mining conditions, how much backfilling should realistically be required? Why is partial backfilling of all cut slopes necessary? In reviewing this issue with Doug Bowman, Mid-Continent' s Environmental Coordinator, and other Mid-Continent officials it was pointed out that the stipulations concerning stability analysis and testing of the mine benches and haul roads were not stipulations to the AOC approval, but rather to the reclamation plans for those areas.