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STATE OF COLORADO <br /> MINED LAND RECLAMATION DIVISION of <br /> Department of Natural Resources yet-g - o <br /> 1313 Sherman St., Room 215 <br /> Denver,CO80203 ** ; <br /> 303 866-3567 1876• <br /> FAX- 303 832-8106 <br /> Roy Romer. <br /> Governor <br /> Fred R.Banta, <br /> Division Director <br /> DATE: January 2, 1992 <br /> TO: Steve Renner r r <br /> FROM: Dan Mathews <br /> RE: NOV C-91-018 Assessment Conference and Related Issues <br /> File C-81-017 (Mid-Continent Resources) <br /> In reviewing the Mid-Continent files in search of information requested by <br /> Jim Pendleton pursuant to the above referenced assessment conference, 1 <br /> discovered that the permit was more specific in regard to interim reclamation <br /> requirements than I had previously thought. The permit contains provisions <br /> indicating that neither cut nor fill slopes would be revegetated, but would be <br /> allowed to slough during the interim period to reduce slope gradients and road <br /> widths. I have found no evidence that we have indicated to MCR that this plan <br /> is inappropriate, or that certain cut or fill slopes should be revegetated or <br /> otherwise stabilized to minimize erosion, siltation and contribution of <br /> additional suspended solids to streamflow. <br /> For these reasons, I assume that Jim Pendleton will vacate NOV C-91-018 as he <br /> has indicated. If the NOV is vacated, I would expect that OSM would re-issue <br /> the TDN and follow up with a federal violation. We might be able to preclude <br /> this by convincing OSM that this situation represents a permit defect which we <br /> are addressing pursuant to INE 35 (4)(C)(5) . We would need to demonstrate, in <br /> this case, that the approved plan which allows for sloughage of both cut and <br /> fill slopes is inconsistent with the approved State program. <br /> A similar situation exists with respect to stabilization/sediment control of <br /> portal bench downslopes. I believe there is some question as to whether the <br /> approved permit complies with the performance standards . I 'm not familiar <br /> with the historical basis for exempting the downslopes from sediment control <br /> requirements , but I would like to discuss the matter with you and determine <br /> how we should proceed. <br /> cc: Jim Pendleton <br /> 0307F/scg <br />