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C-1981-028 RN7 <br />Page 2 <br />According to Page 90 of the permit, Section 2.04.10(4) plant community measurements was <br />"removed and filed" with "Technical Revision 30; Historical Data" and then indicates the current <br />plant community measurements can be seen in Section 2.05.4 of the permit. Rule 2.04.10(4) <br />requires specific information to be included in the permit for baseline vegetation information. It <br />is unclear why this required information was removed from the permit and Section 2.05.4 of the <br />permit does not address the requirements of Rule 2.04.10(4). The Division requests that Coors <br />revise section 2.04.10(4) of the permit to include the information that was taken out and "filed" <br />with TR30. <br />2.05.4(2)(b) — Reclamation Cost Estimate <br />The Division conducted a reclamation cost estimate for the site and found that the liability to reclaim the <br />Keenesburg Strip Mine to be $1,183,605.84. The required surety and currently held surety is <br />$1,197,459.85. Given this, the bond held is adequate at this time. <br />4.03.1(7). 4.03.2(7), 4.03.3(7) — Road Reclamation <br />Page 103 indicates the main access road to the site will be a permanent feature. Page 106 indicates all <br />roads within the disturbed area by mining and reclamation will be removed. However, the Appendix Q-1 <br />Map shows the final Reclamation Contour and Drainage Plan for the site and several of the interior access <br />roads are depicted on this map. Portions of the interior access roads that travel north and west around the <br />A-3 topsoil stockpile and, south and west around Area 25 and the Long Term Spoil Pile are depicted on <br />the Appendix Q-1 Map. Given the permit text on Page 106 and this map, it is unclear if CEC intends to <br />reclaim these interior roads. In accordance with Rule 2.05.4(2), CEC must have a reclamation plan for <br />the roads at the site. This reclamation plan for the interior access and light duty roads needs to comply <br />with Rules 4.03.2(7) and 4.03.3(7). <br />• The operations plan indicates the interior access roads will be removed and reclaimed (page 106 <br />of PAP), however the Appendix Q-1 map depicting the reclamation contours at the site depict <br />portions of these road remaining after site reclamation. Please update the Appendix Q-1 Map to <br />depict the post mine topography of the site with the interior access roads reclaimed. <br />4.05 Hydrologic Balance <br />In order to assure no offsite impacts as this mine moves into the 10 year reclamation period, (see <br />comment above as per Rule 2.04.8), please verify permanent pond and ditch capacities to handle <br />any increases in runoff and provide this analysis to DRMS by verifying: <br />o Detention storage requirement of Sediment Pond 2 <br />o Or, demonstrate to DRMS that the data and values presented in Appendix K-1 of the <br />permit remain valid in 2016 and through 2026. <br />