2004-03-26_REVISION - M1977424 (3)

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= Western Water' & Laud, Inc. / j.ftti~ - ,+ . March 26, 2004 - Mr. Steve Shuey ~ 2 6 ~ L~ Colorado Division of Minerals and Geology / y~ Departrnent of Natural Resources ( ~ >l~ Grand Junction Field Office 101 South Third Street, Room 301 Grand Junction, CO 81501 RE: Response to Logan Wash Mine~l'echnical Revision o. 4)Preliminary Adequacy Review R4sPo~te / (PermitM-771T24)/ Lo~~ Way( Dear Mr. Shuey: Western Water & Land, Inc. (W WL), agent for Occidental Oil Shale, Ina (OOSI), has prepared this letter in response to the Division of Minerals and Geology (DMG) letter of March 24, 2004 which wncerns a preliminary adequacy review of Technical Revision (TR) No. 4 for the Logan Wash Mine. W WL prepared TR No. 4 to address reclamation issues not addressed in the original reclamation plan (Exhibit E) and modify other reclamation methods. This letter addresses the six "Adequacy Issues" stated in your letter. Specify the final disposition of the road berms. The roads to be reclaimed include the upper mine bench road, the Iowa mine bench road, the upper access road, and the lower access road. Berms exist primarily on the outside edge of the mine bench roads and the main upper access road These berms acted as aosion control and safety structures for mine traffic. Tce ditches are not common on these roads (see Photograph No. 1 and 2 in Attachment A). Berms on both edges of the Iowa access road are small to non-existent. Berm material is native gavelly to rocky "soil". Comparatively, the berm material is representative of "top soil" in the area. Native top soil is thin, gravelly and rocky. It is important to note that the "top soil" that existed in the disturbed azeas before disturbance, consisted of these thin rocky, soils on a slope at the angle of repose. In some azeas the road was constructed in existing outcrop with no soils. The soil material originated from mechanical and chemical decomposition of wasting shale colluvium from the exposed ledges and cliffs (Mahogany Ledge). Berms on the upper and Iowa bench roads will be reduced in size and graded back on to the road surface. The berm material will be used as substrate for establishing vegetation W WL proposes to leave a smaller berm to act as a runoff bamer on the upper and Iowa mine bench roads. These roads are on asouthwest-facing slope and maintaining precipitation water on the reclaimed roads will be key in establishing vegetation. The lack of moisture on this slope is probably the single most limiting factor in establishing vegetation here. It is also worth noting that the most vigorous natural revegetation in the mine area ova the last 20 years has been on the edges of the roads; not on sloped areas. The roads will also be ripped prior to seeding to genaate more aerated material. Previous revegetation efforts on roads associated with the mine have been successful without the application of imported soils. AoeGcations m Furth Spence 743 Horiwn Coutt Suite 330. Grand Tunction. CO 81506 Phone: (9701242-0170 Faac: (9701242-0270