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h <br />DIVISION OF MINERALS AND GEOLOGY <br />Dcpanmem u( Namr.tl Rewurces <br />1311 Sherman SI , Konm 21 5 <br />Denver, GJuraAu BO?03 <br />Phone 11031 Afi6-SSLI <br />FAX.I3U 11 BJ? A106 <br />May 4, 1994 <br />III III III 1111111 III <br />STATE OF COLUI~9UU <br />II~~~ <br />I)EPA ItTMENT (7F <br />NATURAL <br />RESOURCE <br />No. Fnnnv <br />l:nu min <br />Attn: Jack Epple ~~•~~.~L~~.~~ <br />Coors Energy E"`°""`'"""""' <br />P.O. Box 359 ""~''"'1° ""'~ <br />Reenesburq, CO 80643 ~~~~~~~"~~~~~~~~~~ <br />Re: Review of 1993 Vegetation Survey <br />Reenesburq Mine (C-81-028) <br />Dear Jack: <br />The Division has reviewed the 1993 Vegetation Report submitted by <br />Coors for the Keenesburg Mine and has the following concerns. <br />1. There appear to be some permit deficiencies in the methodology <br />and statistical demonstrations that are currently being used <br />at the Keenesburg Mine for vegetation surveying. <br />I have included a memo from our vegetative specialist; Tony <br />Waldron for your review and comments. At this time, the <br />Division finds serious permit defects with the methodology <br />being utilized and recommends that Coors consider revising <br />their vegetation sampling methodology. The point intercept <br />method is recommended as an alternative. Using the current <br />methodology, Coors may be inadequately accumulating data that <br />would later be used to support bond release in the future. <br />To address the permit defect and to position Coors more <br />securely for bond release data monitoring and sampling, the <br />Division is hereby incorporating this vegetation review as <br />part of the Mid-term review and requesting that this issue be <br />addressed as a Technical Revision since it would involve a <br />change in monitoring plans. <br />2. Sampling of the vegetation for the last two years was taken in <br />October and November respectively. The permit states that <br />sampling will take place between the months of May to <br />September. This sampling should actually occur between July <br />and September. Sampling during this interval is required due <br />to the length of the growing season for the warm/cool species <br />of grasses. Therefore, based on the time of year the data was <br />collected, the Division considers the last two years data <br />(1992 and 1993) to be approximate and is not considered to be <br />properly representative of the vegetative condition. The <br />