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Clip[! State.co.us Eecutive Branch Mail - Re: Notes from Tuesdays meeting On Wed, Mar 26, 2014 at 1:48 PM, Simmons - DNR, Leigh <1eigh.simmons@state.co.us> wrote: All, want to follow up on some of the action items from our meeting last week. Lorencito • The renewal (RN3) has been approved - you should see the paperwork associated with that shortly. One of the documents you will receive is the Findings - this is a good summary to read and gain some familiarity with the history of the site. On the question of bonding, the Division holds $927,121 and is required to hold $916,169. The RCE (calculated in 2012) was "only" $793,279. The reason for the discrepancy is that $916,169 represents 40% of the amount originally bonded for the areas of the site that have been phase I released. If a phase II bond release application were to be approved, more money could be released, up to 85% of the original bond. The remaining 15% would be held until phase III bond release was approved. This *could* be pro -rated by area, but there are some drawbacks to that approach at a site like Lorencito (since NECC has no plans that I am aware of to use any of the land in the Lorencito permit area, a bond release application for just part of the site would presumably be the result of certain areas not meeting the standards - the result would be that the "bad" areas would then need to be brought up to the standard all on their own, without the "diluting" effect of the "good" areas). • On the question of revegetation standards, section 2.05.4 of the permit describes the approved reclamation plan, within that section, the revegetation plan is described in detail from page 2.05 -60 to -75. A summary of the standards is provided in table 2.05.4 -5 and Map 2.04.10 -1 shows the vegetation community types and identifies the reference areas. I note that "Revegetated areas and the ERA when appropriate will be grazed at an appropriate level for at least two years during the last five years of responsibility for vegetative establishment" - but I'm not aware of any grazing that has yet occurred. The Woody Stem Density standard is 500 stems /Acre and is to be measured along two permanent transects in the Oak /Pinyon community (I'm not sure where they are - do you know Ron ?), and in the fenced shrub plot on the Grassland community. Since shrub transplants were planted in the shrub plot last year, this re -sets the clock for a phase III bond release application for the grassland areas, however, since there is no phase II Woody Stem Density requirement for grassland (see the table), it wouldn't necessarily hold up a phase II application. • Page 2.05 -62 and, by reference, Exhibit 17, describe the reclamation plan for roads at the site. The roads approved as permanent are shown on Map 2.05.4 -2. Most of the roads will be left as permanent structures - the exception being those light -use roads that were constructed during mining AND are not required for use by the gas company. My reading of Map 2.05.4 -2 suggests that the road down to pond 6 is the only significant road that will need to be reclaimed. • On the subject of ponds, although I understand that the desire of the landowner is for the ponds to remain as permanent features I have found nothing in the permit to indicate that this is part of the plan. • On the subject of pond 9 (or 9b, as the NPDES permit calls it), exhibit 15 -14 summarizes the approved designs for all the ponds, including the number, diameter and elevation of weep -holes on the primary spillway riser. For the pond in question, there should be two 2" holes at 6898'. Since the top of the riser is supposed to be at 6904', the lowest holes should be 6' from the top. As the picture shows, the newly drilled holes don't help the riser meet that specification. I would suggest that pond needs to be cleaned of sediment to ensure that it meets all of its design criteria. • John, the 2007 ARR map from Lorencito that I showed you at the meeting is attached Hopefully the results you get from Arcadis will give you some idea of how close you are to a bond release application for this site. NOV CV 2013 -009 1 have not yet been able to complete the adequacy review of TR69, but it is high on my priority list. TR68 The discussion that we had about withdrawing TR68 and starting again in response to RN6 is moot. Kent Gorham came in last week to hand deliver NECC's response to the last adequacy letter. I will review it https: / /mai l.g oog le.com/mai I /u /0 / ?ui =2 &i Ire29129fcb5 &�iev�-- pt &search =i nbox&th= 14519edb76a534d1 &si ml= 14519edb76a534d 1 2/3