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999 <br />STATE OF COLORADO <br />MINED LAND RECLAMATION DIVISION aF.~o~a <br />Departmem of Nawral Resources ~``-=~9 <br />c~ <br />•'z <br />1313 Sherman St .Room 215 ~ <br />Denvor <br />CO 80203 N <br />, <br />~~~' <br />~~ <br />. ~~, <br />303 966 356' 'ra're' <br />Fa %. 3U3 832-8106 ___ <br /> Roy Romer. <br /> Governor <br />November 15, 1990 Fred R. aama <br /> Division D~reaor <br />Mr. Robert Hagen, Director <br />A]buquerque Field Office <br />Office of Surface Mining <br />Reclamation and Enforcement <br />625 Silver Avenue, S.W., Suite 310 <br />Albuquerque, New Mexico 87102 <br />RE: Canadian Strip Mine Phase II Bond Release <br />File: C-81-026 <br />Dear Mr. Hagen: <br />The purpose of this letter is to further explain our reasoning and basis for <br />issuing a proposed decision to approve a Phase II Bond Release request <br />submitted by Wyoming Fuels' for the Canadian Strip Mine and to respond to <br />certain issues raised by Dennis Byrnes in his inspection report dated <br />October 17, 1990. LJe would ask that you reconsider your October 30, 1990 <br />non-concurrence determination, based on the following information. <br />The main thrust of Phase II Bond Release is to demonstrate that topsoil has <br />been replaced and that stabilization of the topsoil resource has been achieved <br />through the establishment of vegetation at the site. As reviewed during the <br />inspection and as later reiterated in the decision document, topsoil had been <br />replaced to an appropriate depth, erosion occurring as the result of a <br />10-year, 24-hour event was less at the reclaimed site than it would have been <br />pre-mining, erosional features at the mine would not detrimentally affect the <br />land use, and ground cover was sufficient to control erosion, between 77q and <br />98~ in the '79-'81 reclamation and between 77% and 86% in the '87 <br />reclamation. On the basis of the high degree of protection afforded the <br />topsoil resource by the mulch and vegetative cover, CMLRD chose to propose <br />Phase II Bond release for the entire site. <br />Generally, it is the Division's policy that revegetation success standards for <br />cover be achieved as a condition of Phase II Bond Release. In this case, <br />although the vegetation cover standard was not achieved within the 52.7 acre <br />area seeded in 1987, it was determined that the ground cover was sufficient to <br />control erosion and protect the topsoil resource. This determination was <br />based on a detailed sediment loss analysis prepared by the operator, as <br />described in the proposed decision document. In addition, erosional stability <br />of the reclaimed areas was quantitatively evaluated during a ,joint inspection <br />on June 20, 1990, using the Erosion Condition Classification System developed <br />by the Bureau of Land i4anagement. The Division's proposed decision to grant <br />the Phase II Bond Release Request was based, in large part, on the computer <br />modeling which indicates post-mine sediment generation is less than would <br />occur under pre-mine conditions, and the field observations which documented <br />the erosional stability of the site. <br />