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_: -. Richartl D. Lamm Governor III IIIIIIIIIIIIIIII sss DEPARTMENT OF NATURAL RESOURCES David H. Getches. Executive Director MINED LAND RECLAMATION DIVISION DAVID C. SHELTO N, Director September 6, 1985 Mr. Henry Barbe Environmental Specialist Powderhorn Coal Company P.O. Box 1430 Palisade, Colorado 81526 RE: Cameo Refuse Disposal Area No. 2 Soils Report - File No. C-041-81 Dear Mr. Barbe: The Division has reviewed the soils report submitted by Powderhorn Coal Company for topsoil stripping operations conducted thus far at Cameo Refuse Disposal Area No. 2. Based on information contained in the report and recent field visits to the site, the Division concurs that all suitable plant growth material has been salvaged from the initial foundation area of the refuse pile. The saline, sodic and/or rocky nature of deeper soil horizons is such that further salvage efforts at the initial foundation area are unwarranted. As development of the disposal pile extends beyond the initial foundation area, however, Powderhorn Coal Company must continue to sample, analyze and salvage all suitable soil material from upland areas as set forth in the approved permit revision. The amount of soil material stockpiled thus far for replacement on CRDA No. 2 is considerably less than the amount required to meet the four (4) foot minimum cover requirements set forth in Rule 4.10.4 (4). Even with the additional material anticipated to be salvaged from upland areas, the total amount planned for replacement over the completed pile will be insufficient to meet the 4 foot minimum cover requirements. The Division understands that Powderhorn Coal Company is conducting field trials on the nearby Roadside refuse pile to determine if less than 4 feet of material will be sufficient to achieve successful revegetation and minimize disturbance to the hydrologic balance. At the present time, however, the field trials have not been completed and the Division must require that Powderhorn Coal Company meet the 4 foot minimum cover requirements of Rule 4.10.4 (4) until results of the field tests conclusively demonstrate that less than 4 feet of cover is sufficient. In this regard, Powderhorn Coal Company must submit information to the Division demonstrating that additional quantities of non-toxic, non-combustible fill material can be obtained from areas adjacent to CRDA No. 2 in an amount sufficient to meet the 4 foot minimum cover requirements. 423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203 Tel. (303) 866-3567