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M~orandum To: Byron Walker CC: Dan Hernandez From: Janet Binn Date: 9/01 /2004 Re: Colowyo Coal Company, C-1981-019, TR-56 operator's August 2Q, 2004 adequacy responses Byron, I have reviewed Colowyo's responses to the Division's adequacy letter dated May 13, 2004. Colowyo's responses were received by the Division on August 20, 2004. I have included my May 13, 2004 memo and included my review of Colowyo's responses in Blue. Green text was from the Division's adequacy memo to Colowyo dated August 8, 2003. On revised Appendix 13, page 10 (rev. 3/31/04), Colowyo attributes $41,085 to the approval of TR-49. DMG records show the approval of TR-49 resulted in an increase of the reclamation liability of $31,876.00. Is this difference in liability associated with TR-49 due to actual costs involved upon construction, or a typographical error? If Colowyo's $41,085 cost is correct, Colowyo does not need to change this value. Colowyo's response is acceptable 2. Review of the May 3, 2004 submitted permit pages found the Appendix 13: page 13 had differences in reported acreage. Disturbed acreage associated with the East Pit were reported as 42 acres less than previously assigned. Are these acres accounted for elsewhere in the estimate? Did these 42 acres undergo phased bond release process, or is this a survey correction to the previous acreage. The West pit disturbance area was decreased by 107.3 acres. The same questions apply to these west pit acres. Section 16 disturbance area increased by 177.8 acres based upon the revised pages. Colowyo replies indicate that the updated acreages as the actual acreages. Appendix 13, page 13 reports the total disturbed area as 2,094.70 acres, yet the same page reports 2,400.2 acres having been previously seeded. How can the disturbed acreage be less than the seeded acreage? Does the disturbed area represent those acres still needing backfill and grading? Neither of these= numbers reported by Colowyo agree with the values reported in the CDMG database. The Division needs further explanation of what these acreage numbers mean. Colowyo did not address this discrepancy. These acreage values will need to be addressed in future permitting actions. Appendix 13, revised page A-4 reports all zero volumes. What is this table showing, and why are all the values zeroes?