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F DIVISION OF MINERALS AND GEOLOGY Department of Natural Resources 1313 Sherman St., Room 2 ] 5 Denver, Colorado 80203 Phone: (303) 866-3567 FAX: (303) 832-8706 COLORADO DIVISION O F MINERALS GEOLOGY REC LAM ATION•MINING SAFETY•SC IENCE SFP 2 9 2005 DATE: September 27, 2005 TO: Mike Boulay FROM: Dan Mathews RE: 2004 Revegetation Monitoring Report Yoast Mine, Permit No. C-94-082 Russell George Executive Oirec[ar Ronald W. Cat[any Division Direnor Natural Resource Trustee Per your request, I have reviewed the 2004 Annual Revegetation Report prepared by ESCO Associates, Inc. !also reviewed sections of the 2004 Annual Reclamation Report, pertinent to topsoil and revegetation. My comments with respect to the Annual Reclamation Report and the Annual Revegetation Report are listed below. 2004 Annual Reclamation Report On page 1 of the report narrative, SCC states that "average replacement depth for the 2004 area is 1.3 feet". On page 2 of the report narrative, a soil balance calculation is provided, which indicates that sufficient soil is available in stockpile to replace a thickness of 1.2 feet in the mine area. In subsequent narrative, SCC indicates that "enough topsoil has been salvaged to reclaim the existing disturbance with the permitted minimum replacement thickness of 1.0 foot". This would appear to be the case, however Tab 21 of the approved permit states that "an average of 1.8 feet of soil will be replaced", with a "minimum thickness of 7.0 feet..." in the mine area. Lesser thickness is specified for roads and shrub island areas. It would appear from the information provided, that the specified average replacement thickness of 1.8 feet for the mine area was not met in 2004, and that stockpiled soil volume may be insufficient to meet the specified average replacement thickness in the future. Please address the reasons for the apparent deficit with respect to average soil replacement thickness in the 2004 reclamation area and for future reclamation areas, and address how the apparent non-compliance with permit requirements will be resolved. Also, please provide a sketch or map of the 2004 reclamation parcel showing soil depth sample locations and measured thickness for each location. 2. A copy of a seed tag, two certification letters from Granite Seed Company, and Table 04.2 were submitted, to document seed mix components used in the 2004 seeding. There seem to be a number of contradictions and inconsistencies in the information submitted, and between documentation submitted and the approved seedmix. a) The approved mix specifies Secar bluebunch wheatgrass, whereas Table 04.2 specifies beardless bluebunch (var. inerme). The seed tag and both certification STATE OF COLORADO Divislol~ c; :finerals & Geologysili ow-ens Governor Office of Office of Colorado Mined Land Reclamation Active and Inactive Mines Geological Survey