2015-01-20_REPORT - C1981022

• Permit No: C1981022
• IBM Index Class Name: Report
• Doc Date: 1/20/2015
• Doc Name: 2011 and 2013 Annual Reclamation Report Review Memo
• From: DRMS
• To: Oxbow Mining, LLC
• Permit Index Doc Type: Annual Reclamation Report
• Email Name: TNL
• Email Name: DIH
• Media Type: D
• Archive: No

Tabetha Lynch, DRMS
Page 4
January 20, 2015
For 2011 and 2013, weed control activities were conducted on disturbed areas such as
road cuts, warehouse storage areas, pond outslopes, reclaimed borehole roads and
borehole pad- sties. A rill and gully survey was conducted 2011.
(f) As indicated above, Oxbow provides a list of all the areas seeded at the site, their
respective acreage and the year the area was seeded.
(2) No additional monitoring information was provided with the 2011 and 2013 report.
Based on the review discussed above, the Division has the following concerns:
A. The status reported for the disturbed areas in Exhibit 1 of the report is unclear. Many
disturbed area parcels are indicated to have been reclaimed; however upon further review,
many parcels have only been partially reclaimed as only portions of the disturbed area have
been reported to have been seeded. Oxbow should review the status of the areas reported
to have been "reclaimed ", and make clear under what land status these areas are
categorized, such as backfilled and graded and topsoiled, Oxbow should account for this
reclamation in the ARR as required by Rule 2.04.13.
B. According to the 2013 ARR, for the following parcels; GVB- LW9 -04, GVB- LW10 -02, GVB -
LW10-04, GV1311 -01A, GVB- LW16 -06, GVB- LW16 -07 and GVB- LW17 -09 the amount of
acres reported to have been seeded is greater than the acres reported to have been
disturbed. Oxbow needs to compare the acreage they have reported to have seeded to the
disturbed areas acreages for each of the parcels and fix any discrepancies.
C. According to the 2013 ARR, the following areas were reported to have been seeded, but do
not appear to correspond to any of the disturbed areas listed in Exhibit 1;
0 S. East Yard Coal Mine Waste Pile
0 8. A -1 Gulch
0 22. TC1 and TC2 Well
0 25. GVB- LW12 -03 pad
0 28. GVB - LW8 -02, 2800 feet of road
0 29. GVB- LW10 -OBC
o 32. GVB - LW8 -02 Pad, 1600 feet of road
The acreage associated with these areas totals 8.86 acres. No acreage was reported for TC1
and TC2 Wells. Oxbow will need to evaluate these parcels and add them to the disturbed
area listed in Exhibit 1 and update the total disturbed area as appropriate.