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31. It was common practice several years ago at the Colowyo Mine to rip, scarify or otherwise <br />roughen the recently replaced topsoil at the mine prior to reseeding. This was often <br />accomplished by using a dozer to rip the topsoil on contour. The main benefit of this <br />practice was to reduce the erosion potential from rain and spring runoff. A secondary <br />benefit is that the pond receiving the runoff the Prospect Pond, in this case) will not receive <br />as much sediment. This practice has been discontinued in the last few years. On site <br />inspections this spring (see in particular the 16 April 2008 inspection report) it was evident <br />that water is flowing uncontrolled over the recently reclaimed surface, causing extensive <br />rilling. This year the snowmelt was pretty gradual and there was still some damage to the <br />reclaimed surface. In years where the snowmelt is faster, the results could be catastrophic. <br />The Division would like to see this practice restarted and requests that Colowyo <br />include a commitment to use surface roughening techniques on all areas where topsoil <br />has been replaced at the Colowyo Mine. <br />This concludes the preliminary adequacy review for the Colowyo Mine Technical Revision 72. The <br />Division would like to have this revision approved and in place so the new reclamation plan can be <br />implemented in this (the 2008) reclamation season. As such, the Division requests your response to <br />the above questions no later than 20 May 2008. Since this response date is also the proposed <br />Decision deadline, the Division requests that Colowyo request a decision extension until 12 June <br />2008. Please call me at (303) 866-4929 if you have any questions or need any additional <br />information. <br />Sincerely, <br />James R. Stark <br />Environmental Protection Specialist <br />Attachment <br />cc: Sandy Brown <br />Dan Mathews <br />Jon Wangnild, DOW <br />Colowyo Coal Company, C-1981-019 TR-72 <br />April 29, 2008 Page 15 <br />