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,: JUN i 62005 `~ fJ~tsd n FFsOd CK1~9 CJ"raic~*tsn of ~ R+ tiieattr0y Mr. Steve Shuey ~'Wsion of Minerafa aa~ Geoto Colorado Division of Minerals and Geology gy Grand luncfion Field Office 101 S. 3"~ St. Suite 301 Grand Junction, CO 81501 / RE: (Investigatiou of Soil Barrow Sourtxs~iu theLLogan Wash Miu~A>r~Permit M-1977-424 "'"` _ Western Water & Iand, Ire. '-~ ~~ ~,~' °~ -a~ED June 15, 2005 . JUN 2 ~ 2005 Deaz Mr. Shuey: Western Water & Land, Ina (W WL) as agent for Glenn Springs Holdings, Inc., property manager for Occidental Oil Shale, Ina (OOSI), has conducted a preliminary surface investigation of soil sources in the Logan Wash Mine area for soils to be harrowed for use in reclaiming the Logan Wash Mine lands. The Reclamation Plan, as revised in Technical Revision No. 4, described revegetation methods that did not include the use of soil amendments. However, experiments conducted at the mine last yeaz indicate that the application of soil amendments is necessary to attain reclamation goals in a reasonable time flame. OOSI therefore proposes to import soil substrate on most of the affected land surfaces to more effectively establish native vegetation. W WL intends to describe the application of soil amendment in an upcoming technical revision. The purpose of this letter is to inform you of the results of an initial soil source investigation and ask for a formal position from the Colorado Division of Minerals and Geology (DMG) on the designation of "affected areas" originally associated with Permit M-1977-424. This is significant in that the harrowing of potential soil sources within affected areas can be addressed through the technical revision process, whereas lands designated as not within affected areas must be addressed through the submittal of a new 1 ] 0 permit. Initially, it was estimated that as much as 7,000 cubic yards of soil would be needed to meet reclamation needs for the areas identified in Technical Revision No. 4. This volume was based on a total reclamation acreage of 14.7 acres (Lower and Upper Bench, Lower and Upper Bench Roads, Research Mine Bench, and Main Access Road). However, subsequent discussions between OOSl and Occidental Gas Company indicate that tale latter company is interested in the Lower Bench as a future gas well location. If such activity occurs, the Lower Bench and Main Access Road will not require reclamation under DMG regulations. In addition, the U.S. Bureau of Land Management (BLM) has suggested that the Lower Access Road not be reclaimed. Therefore, the remaining acreage that is scheduled to be reclaimed includes the remaining portion of the Upper Bench and Upper Bench Road, the Lower Road section on OOSI lands, and possibly portions of the recontoured Research Mine Bench. These affected areas total approximately 2.5 acres. With a proposed amendment cover of a minimum of 4 inches, the volume of soil required for the 2.5 acre area is approximately 1,500 cubic yards. The soil source surface investigation consisted of the inspection of lands within the contiguous ownership of OOSI within reasonable distance of Logan Wash Mine. Thin soil cover and topographic conditions severely limit the availability of soil in the area within a few miles of the mine. Applications m Earth Science 743 Horizon Court Suite 330, Grand Junction, CO 81506 Phone: (970) 7A2-0170 Fa~c: (970) 7AZA270