GENERAL53277

• Permit No: C1981026
• IBM Index Class Name: General Documents
• Doc Date: 3/22/1990
• Doc Name: Midterm Review Findings Document
• Permit Index Doc Type: Findings
• Media Type: D
• Archive: No

I. Decision to Require Revision
Based on this mid-term review the Division finds that certain revisions
and modifications are needed to insure future compliance with the
Colorado Surface Coal Mining Reclamation Act and the Regulation of the
Colorado Mined Land Reclamation Board for Coal Mining. The following
section details the revisions required, justification for requiring the
revisions and timetable for submitting the revisions. Responses should
be submitted as one package by April 30, 1990.
Land Use - Rules 2.04.3, 2.05.5 and 4.16
1. The Land Use Appendix references the M&T Oil Well. Does the pipeline for d~
this well or any other well run through the permit area? (Rule 4.04.6).
Topsoil - Rules 2.04.9, 2.05.3(5), 2.05.4(21(d) and 4.06

2. The permit application should be revised to reflect that only 6 inches of
topsoil was required on the 81 acres that were reclaimed in the summer
of 1987. Page 61 of the application states "Wyoming Fuel estimates
sufficient soil available to cover the entire reclaimed land surface to a
depth of approximately 21 inches." Appendix E reiterates this
projection. While permit corresponaence in the file notes that only
0.5 feet of topsoil was required for replacement in 1987, this
information 1) confl icts with the main body of the application, and
2) is not referenced in the main body of the application. The
application should also correctly specify how much topsoil was replaced
on the disturbed area reclaimed in 1981.
3. Two soil testing plans were found in the permit application and
correspondence; one in 1981 and another in 1987. Wyoming Fuels made the ~`~
following commitment in Exhibit l: "Wyoming Fuel (will) test the soil
for fertilization every year for the next three years. As soon as the
results of the soil tests are available they are to be forwarded to the ~,
Division. At the end of three years WFC must request that the Division a
terminate the soil test requirement and include the necessary soil test s~tl~
data that justifies the termination." This commitment stemmed from a
1981 minor revision and thus would have required sampling through 1984 at~
least. Required submittals cannot be located in the permit ;
correspondence. Please submit all pertinent information regarding this
minor revision. The Division would prefer that this soil sample data and:
other communications resulting from this plan be prepared as an inclusion.
to Exhibit 1 and that the permit application (page 65) reference this ~•
data. Additionally, please indicate to the Division the relationship
between the soil plan outlined in Addendum 2 and the soil plan noted in
Exhibit 1.
The permit application does not presently address a soil testing plan for
the area reclaimed in 1981. Response 4 of the September 19, 1986 letter
from David Stout to Steve Renner {RE: Response to Adequacy Issues,
TR-03, Reclamation of Canadian Strip Mine) committed to a program for
testing topsoil for nitrogen, potassium, phosphorous, and pH. Please
revise the application appropriately to indicate what testing was done,
what sampling methodology was followed, what results were obtained ana
whether fertilization was necessary and carried out.
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