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iiiiiiiiiiiiiiuiii 999 STATE OF COLORADO DIVISION OF MINERALS AND GEOLOGY Department o(Natural Resources 1313 Sherman 51., Room 215 Denver, Colorado 80203 Phone: (303) 866-3567 FAX: (303) 832-8106 DATE: June 7, zooo RECEIVED TO: David Berry /I ~l^(/~fl-E' JUN U E 2000 FROM: Dan Mathews ~,r~ RE: Roadside Mine Technical ~iglon 32"~ ~'~j~l~y Revision Order Response (Mine Closure Reclamation Changes) Permit C-1981-041 DIVISION OF MINERALS GEOLOGY RECLAMATION MINING•SA FETY Bil I Owens Governor Greg E. Walther Executive Director Michael B. Long Division Director David, I have enclosed two sets of Powderhom Coal Company's (PCC) TR-32 application, which was submitted in response to our Revision Order letter of February 18, 2000. I have also enclosed two copies of the Revision Order letter. 1 would like to request review assistance with respect to geomorphic implications of revised final configuration and diversion design for refuse areas CRDA-1 and CRDA-2 (Item 6), as well as hydrologic review associated with the proposed new CRDA-2, 100 year upland diversion (Item 6). Also, note that, in Item 9, operator is complying with our suggestion to remove the large rock drop struMltres from the relocated Coal Creek permanent diversion segment If there are any hydrologic or geomorphic objections to this proposal, we need to raise them now. Finally, I need a hydro[ype to review the proposed sediment convol plan for the Unit Train Loadout, reclaimed configuration (Item 12), and at some point I will need a hydrologist to review the Culver removal low water crossings (Item 10), assuming BLM signs off and such plans are submitted. ]im Pendleton was instrumental in recommending removal of the rock drop stmMures fiom the stream channel, and expressed some interest in the geomorphic concerns relating to the CRDA-2 final topography and upland diversion issue. If he is willing and available, it would be good to have him take a look at Ule proposal. I don't know which surface hydrologist is least bogged down these days. Mike Boulay seems to get stuck with most of my sediment/drainage control reviews, but you can assign it as you deem appropriate. i'll be calling the submittal complete on June 15, and would like to request review memos by July 10. Note that Stover states a couple limes that the proposed changes should not result in any additional reclamation cos[. 1 am sure he is under pretty strict marching orders to avoid increased reclamation costs if at all possible. The current liabibty amount and the current bond amount are identical, and Utey do not want to increase the bond. Our midterm review is due July 3. I plan to have Jim Stark update the wst estimate for the midterm, and subsequently amend that updated estimate as appropriate for Ulis revision. With regard to the Bond, a Quaker Coal official I met last week at the mine who is apparently calling the shots (or Powderhom now, mentioned that the insurance company they use (or most of their reclamation bonds back east is in financial Vouble (he mentioned bankruptcy and possible takeover by another company). The company he referred to is Frontier Insurance of New York, issuer of a S2.6M surety we hold for Roadside. Is there anything we should do with this information at this time? Also, the company has made it clear that they do not plan to initiate any large scale reclamation projects (such as refuse area final reclamation) until 2001, which is allowable under their currently approved reclamation schedule (which basically specifies initiation of reclamation within one year of mining cessation). They mentioned the possibility (pretty unlikely I imagine) that PSC miglll be interested in modifying their Cameo plant to burn refuse from [he waste piles at the mine, if they can qualify for some program whereby they would be subsidized by the feds. 1 said to keep us posted, but if there wasn't something pretty concrete to indicate that this was real, we would require that refuse area final reclamation be initiated in accordance with approved plans in 2001.