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III IIIIIIIIIIIIIIII <br />999 <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Depanmem of Natural Resources <br />1313 Sherman 51., Roam 215 <br />Denver, Colorado 80207 <br />Phone. (3071 866-3567 <br />FA%:1303) 832-8106 <br />November 5, 1996 <br />Mr. John Walters <br />Grand Valley Coal Company <br />P.O. BoX 70 <br />Loma, Colorado 81524-0070 <br />RE: Munger Canyon Mine (Permit No. C-81-020) <br />Technical Revision #11 (Reclamation Plan for <br />Disturbance) <br />Dear Mr. Walters: <br />v <br />~,s <br />U~b~ n <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br />Foy Rnme~ <br />Govcrnw <br />lames 5. Lochhcad <br />6eanive Director <br />Mir hac B. Long <br />Division Uueaw <br />Existing <br />The Division has reviewed the revised permit application narrative, <br />maps, stability analyses and reclamation cost estimates associated <br />with TR-11, and our specific review comments are listed on the <br />enclosed pages. TR-11 was submitted in response to Stipulation No. <br />22, attached to TR-10. The stipulation states: <br />PRIOR TO RESUMPTION OF ACTIVE STATUS, AND NO LATER THAN <br />JUNE 1, 1996, THE OPERATOR WILL SUBMIT A COMPLETE PERMIT <br />REVISION APPLICATION ADDRESSING RECLAMATION OF THE <br />EXISTING ROAD AND PORTAL BENCH DISTURBANCES. THE <br />APPLICATION WILL CONTAIN APPROPRIATE MAPS, CROSS <br />SECTIONS, AND NARRATIVE DESCRIBING THE EXISTING ACCESS <br />ROAD AND ASSOCIATED DRAINAGE CONTROL FEATURES, ALONG WITH <br />A DETAILED RECLAMATION PLAN WITH APPROPRIATE CROSS <br />SECTIONS DEMONSTRATING COMPLIANCE WITH THE REQUIREMENTS <br />OF RULE 4.03.2. THE APPLICATION WILL FURTHER CONTAIN A <br />DETAILED BACKFILLING AND GRADING PLAN FOR THE PORTAL <br />BENCH DISTURBANCE AREA, WITH APPROPRIATE CONTOUR MAPS, <br />CROSS SECTIONS, AND ANALYSIS AS NECESSARY TO DEMONSTRATE <br />COMPLIANCE WITH APPROXIMATE ORIGINAL CONTOUR, 1.3 MINIMUM <br />STATIC SAFETY FACTOR, AND HIGHWALL ELIMINATION <br />REQUIREMENTS OF RULE 4.14. <br />In addition to the plans and analyses specified in the stipulation, <br />the revision application includes a revised reclamation cost <br />estimate based on reclamation of the existing disturbance only. We <br />have reviewed the cost estimate, and prepared our own estimate <br />which is enclosed. It would appear that a substantial bond <br />reduction will be approvable if the bond amount is based solely on <br />the cost of reclaiming the existing disturbance. You need to be <br />aware, however, that in order for us to allow for a reclamation <br />bond amount covering only the current disturbance, our approval of <br />