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Mr. James R Stark <br />Colorado Diviriou ojMinerak d7 Geohgy <br />Augurt 7, 2002 <br />Page 3 <br />Response: The original soil sampling plan, as referenced in Comment 14, is consistent with standard <br />practices and would be appropriate under normal nvnnig and reclamation conditions. Extensive historic <br />mining in this azea, however, resulted in loss or contamination of available soil resources so that there is a <br />significant soil deficit relative to available soil resources for final reclamation. EFCI has taken all reasonable <br />steps to maximize the benefits of the available soil, including developing a borrow source for the soil cover <br />for the coal refuse pile and importing soil materials from the adjacent Newlin Creek Mine property. While <br />soil sampling and analysis for soil nutrients and development and implementation of a soil conditioning <br />program (if indicated by the analyses) aze still appropriate and could be beneficial relative to revegetation <br />success, sampling and analysis for sod suitability and any associated remedial measures aze no longer practical <br />since no other soil materials are available for remediation. EFCI, therefore, requested approval to drop the <br />suitability sampling and subsequent remedial measures and Focus their efforts and resources on optimizing <br />utilization of the existing available soil resources. <br />Discussion with CDMG and review of relevant permit materials resulted in agreement that soil sampling <br />requirements could be reduced to the top 1.0 foot of the replaced soil profile and the soil analysis pazameters <br />could be reduced to the fertility pazameters of nitrogen, potassium, and phosphate, and the salinity <br />parameters of calcium, magnesium, sodium, and SAR. Based on this revised sampling program, soil sampling <br />will be completed and analysis results and any soil conditioting recommendations will be provided to the <br />CDMG prior to completion of permanent seeding in the fall. Corresponding permit text has been revised <br />and copies of the revised pages are included with this TR submittal. <br />RULE 4.10 <br />Comment L5 -This comment was previously addressed in the TR-33 submittal. <br />RULE 4.75 <br />Comment 16 -EFCI bar hvo propnred reed mixer. Table 33 lirtr a need mixfar temporary reeding and ako a list far <br />permanent reeding. Given that EFCI i r tonduding permanent reclamation, there will no !anger be a need for the temporary mix. <br />Please confirm that thir it a tamed arrumption. <br />The permanent reed mix containr two introduced rpecier that the DMG rtron~ discourager. They an introduced rpecier that <br />are not ar ben~~zal far the port miming land ure ar cnmpara6le native rpecier. Specifrtalfy, Ctrrted IY/heatgrarr and Internrediate <br />W/heatgreur rhould be removed from the mix. There are both cool reason gnurer that could be replaced with Indian ricegrarr <br />(Achnarherum hymenoides), I~Teedle and thread (Stipa tomato), Munongrarr (Poo fenleriana), Beardlerr bluebuncb <br />wheatgrarr (Pseudorogeneria spicata ssp. inermis), oranotberappropriate nativegrxrrr. <br />The dircurrianr on pager 2.05.4-22R and 4.15-2$ Ure of Introduced Specier, rhou/d be nvi red actardin~ with the revised .reed <br />mix. <br />The reeding rate that EFCI hay propored of 6.55 Ibr/acre teems appropriate. However, DMG aGo looks at the PLS'lft2. <br />Generally, DMG recommendr approximately 20 PLS/ft' and EFCI i.r proporing 49 PLS/ftz. EFCI may want to educe <br />the reeding rate to reduce the number of reedy per rquare foot. <br />Response: MR-45, submitted 5/28/02 and subsequently approved, eliaunates the temporary seed mixture <br />and proposes temporary seeding, due to current drought conditions, with aquick-growing cover crop of oats <br />to stabilize the soil and m+nimi>e erosion of reclaimed azeas until permanent seeding can occur. <br />The permanent seed mixture has been reviewed with regazd to the CDMG's comments and Crested <br />wheatgrass and Intermediate wheatgrass have been elvninated and replaced with Indian ricegrass and <br />Beazdless bluebunch wheatgrass, which aze both cool-season, drought-tolerant speaes suited to the <br />