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II I I II I ii l 11 llil ill <br />999 <br /> <br />STATE OF COLORADO <br />Roy Romer, Gove <br />DEPARTMENT OF NATURAL RESOURCES <br />MINED LAND RECLAMATION DIVISION <br />DAVID C. SHELTON, Dlreetor <br />Date: November 6, 1987 <br />To: Susan Mowry d{/ <br />~~~ <br />From: Peter O'Connor <br />Re: SOMERSET MINE TECHNICAL REVISION N0. 5, PERMIT N0. C-81-022 <br />As requested, I have reviewed the responses submitted by Kaiser Steel <br />Corporation to address adequacy concern No. 8 of your September 22, 1987 <br />letter. Besides reviewing this response, it was also necessary for me to <br />review Appendix H of Technical Revision (TR) No. 5 and Appendixes G and H of <br />the approved permit document. During this review a number of concerns were <br />identified as addressed below. <br />A. Background <br />Appendix G of the approved permit document presents the baseline vegetation <br />inventory performed by Western Resource Development (WRD). The baseline <br />inventory was agreed upon by the Division and represents an inventory of the <br />surrounding areas since mine development commenced in 1902 prior to the need <br />to perform baseline inventories. fie baseline inventory will be used for <br />comparison purposes of reclaimed areas as allowed by Rules 4.15.7(2 )(d )(iii) <br />and (iv). <br />Appendix H of the approved permit document is the approved revegetation plan <br />developed by WRD based, in part, on the vegetation baseline inventory. <br />Appendix H of TR No. 5 is a request to completely modify the approved <br />vegetation plan. No rationale is provided as to why the approved vegetation <br />plan should be modified. <br />Concern No. 8 of your September 22, 1987 letter is a request for additional <br />information pertaining to evaluation of revegetation success and to shrub <br />establishment. The Kaiser Steel submittal of November 2, 1987 is an attempt <br />to address the identified deficiencies. <br />B. .4ppendix H Concern <br />A comparison was made between the approved revegetation plan and the proposed <br />revised plan of TR No. 5. A number of changes have been proposed to the plan <br />as addressed below. <br />423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203-2273 Tel. (303) 866-3567 <br />