GENERAL43949

• Permit No: C1981034
• IBM Index Class Name: General Documents
• Doc Date: 1/26/1996
• Doc Name: Midterm Review Findings Document
• Permit Index Doc Type: Findings
• Media Type: D
• Archive: No

III. SUMMARY OF CHANGES REQUESTED
Pursuant to Rule 2.08.3, the Division has conducted a midterm
review and finds that certain revisions and modifications are
needed to ensure future compliance with the Colorado Surface Coal
Mining Reclamation Act and .the Regulations of the Colorado Mined
Land Reclamation Board for Coal Mining. This section details the
revisions required and an explanation of the reason for requiring
the revisions.
Changes requested below should all be addressed within a single
technical revision which should be submitted to the Division by
April 1, 1996.
2.04.9. 2.05.3(51. and 2.05.4(21(dl
1. There are various contradictory statements in the permit
application and most recent findings document regarding whether any
topsoil was ever salvaged and replaced. It is clear that certain
areas where topsoil was available ("D" Portal area, new sediment
pond, and pinyon-juniper habitat adjacent to the refuse disposal
area) were never disturbed, and various statements in the permit
application indicate that, due to pre-law disturbance in the
affected area, no topsoil was salvaged. However, there are also
statements in the text indicating that topsoil would be salvaged,
and Table 2.05.4(2)(b)-4 revised 3/3/89 indicates that 675 c.y. of
topsoil was salvaged from the vicinity of the underground
development waste disposal area.
The application should be updated to describe the source and
quantity of any topsoil salvaged, the location on the reclaimed
area where topsoil was respread, and the replacement depth on that
area.
2.04.10 and 2.05.4(21(el
2. Rule 2.05.4(2)(e)(vi) requires that the reclamation plan
include a description of measures proposed to be used to determine
the success of revegetation in accordance with 4.15.7. Rule
4.15.7(1) requires that success of revegetation be measured by
techniques approved by the Division, and states that consistency in
sampling methodology shall be required in comparisons between the
reclaimed area and undisturbed areas. Rule 4.15.7(2}(a) requires
that the plan discuss applicable success criteria, (b) requires a
description of measurement methods, (c) requires a description of
statistical tests of success, and (d) requires a discussion of the
comparisons to be made between reclaimed and undisturbed areas.
The permit application does not address these issues in an
organized, comprehensive fashion, and needs to be updated.
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