GENERAL38867

• Permit No: C1981019
• IBM Index Class Name: General Documents
• Doc Date: 11/20/2000
• Doc Name: Midterm Review Findings Document
• Permit Index Doc Type: Findings
• Media Type: D
• Archive: No

C-81-019 2000 Midterm Review
November 20, 2000
needed (PAP, page 2.05-58). No schedule for demolition of structures was found during this
review.
Please add a thorough description of facilities demolition in the detailed timetable of the
reclamation plan.
Item 30. Rule 2.05.4(2)(b). A detailed estimate of the cost of reclamation is provided in Exhibit
l3. The Division conducted [using a computer assisted program titled Colorado Integrated
Reclamation Cost Estimating System (CIRCES), developed as a cooperative project between the
Division and the Office of Surface Mining Reclamation and Enforcement (OSMRE)] a cost
estimate for comparison with Colowyo's estimates of the following key reclamation task costs:
structural demolition, earthmoving, topsoil redistribution, ripping, and seeding, and drill hole
reclamation. Cost estimating worksheets are at Attachment A (Tasks 100 through 112, 1 IS
through 123, 125 through 135, 137 through 147, 150 through 158, 160, 161, l63 through 168,
and 200). The finding of this review is that the reclamation costs for the selected tasks are now
estimated at $459,896 more than [he currently approved estimates, and that the current bond
coverage needs Co be raised by $145,570 plus associated indirect costs to cover the total estimate
of reclamation costs. A concurrent action, Technical Revision 50, transfers reclamation liability
for exploration and monitoring holes (Task 168 of the estimate) from the Permit to Exploration
Notice of Intents (NOI). Upon approval (anticipated in this mid-term review), both the increase
in the estimate and the required increase in surety would be reduced by $4,991. The cost
comparison analysis at Attachment A does not include indirect costs.
Please revise the cost estimate of Exhibit 13 to reflect the increase in estimated direct
($135,597), and associated indirect, costs. Please provide a rider to the Reclamation Bonds
held by Colowyo Coal Company, L.P. to cover the total revised estimated cost of
reclamation.
Item 31. Rule 2.05.4(2)(c). The PAP is in compliance with this rule (see reclamation plan above).
The postmining contour (topography) and cross-sections are on maps 19, 19A, 20 and 20A.
Details of drainage profiles aze on Maps 33 and 33A. A number of maps and cross-sections (34,
35, 36, 38, 39 and 40) illustrate details of the postmining plan.
Item 32. Rule 2.05.4(2)(d). The PAP is in compliance with this rule. The topsoil plan starts on
page 2.05-2 of the PAP. Topsoil removal schedules and stockpile locations are delineated on
Map 28. See also Tables 1 (Topsoil Schedule for Mining Area), and Table 2 (Topsoil Removal
Plan). Direct haul of topsoil from a site to a reclaimed graded portion of the reclamation is a
usual practice (PAP page 2.05-42).
Item 33. Rule 2.05.4(2)(e). A revegetation plan is provided in the PAP. Revegetation is
contemporaneous with mining reclamation, with seasonal planting periods. Species schedules aze
in Table 7 of the PAP. Seed mixes aze approved, but a comprehensive seedling schedule is not
described. A statement is provided that "Depending on availability and price the following shrub
species will be planted as seedlings: servicebetry, Gamble's oak, bitterbrush, snowberry, sumac,
chokecherry, wild rose, and other commercial shrub species available on the mazket that are
suitable to the conditions found at Colowyo." on page 2.05-52 of the PAP. The Division finds
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