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6. Section 8 details the regraded spoil sampling as required in the PAP. The <br />spoil sampling data is contained in Exhibit 8-3 of the report. More <br />specifically, the 2007 sample data is contained on Page 8-8 of Exhibit 8-3. <br />Four sample locations, J-21, 1-20,1-21 and 1-22, show slightly elevated levels <br />for SAR (all above 5) but well below the suspect level (of 15) that triggers <br />additional sampling and possible remedial actions. Colowyo did not, <br />however, include a map or plate that shows the locations of the samples. <br />Please provide the Division with a map or plate that shows the locations <br />of the 2007 overburden samples. <br />7. Section 9 of the Annual Reclamation Report contains detailed information <br />regarding second, forth and seventh year vegetation monitoring for the East <br />Pit, West Pit and Section 16 Pit. All of the reclamation units that were <br />required to be monitored, based on the above schedule, are included in Exhibit <br />9A, 2007 Revegetation Monitoring Report. One note of interest is that there <br />are approximately 755.07 acres that have been backfilled and regraded and <br />may meet the criteria for application for a Phase I Bond Release. There are <br />521.57 acres that have been reclaimed for five-years or more and may be <br />eligible for a Phase lI Bond Release. <br />8. Section 11 of the Annual Reclamation Report contains information regarding <br />the Colowyo Mine's topsoil volume inventory. Exhibit 11-1 details the areas <br />that have been reclaimed and the replacement volumes and calculated depths. <br />Exhibit 11-2 details topsoil stockpile volumes (including stripping and <br />replacement activities). Figure 11-3 details topsoil movement during the 2007 <br />reporting year. All of this information indicates Colowyo is stripping all <br />available topsoil resources and that they will have adequate topsoil resources <br />for their required reclamation forward. These replacement depths are <br />calculated depths. The Division would like to know if Colowyo has dug <br />any test holes in the field to verify replacement depths. Additionally, <br />there is one text error on page 11-5 of the ARR. The "note" below Figure <br />11-3 refers to Exhibit 7. This Exhibit has been renamed Exhibit 5A in the <br />ARR. Please correct the reference in the "note" to the correct Exhibit <br />5A. <br />9. In 2007 Colowyo regraded 42.2 acres in the West Pit. The area that was <br />regraded is an "island" reclaimed with the 102 dragline as Colowyo was <br />preparing to walk it into a cut in the West Pit. Based on conversations during <br />recent inspections, Colowyo has stated they do not plan to topsoil or seed this <br />`island' until the contiguous areas are regraded and seeded. Map 29 - Spoil <br />Grading - South Area, shows that Colowyo committed to have approximately <br />430 additional acres regraded in the West Pit by the end of 2007. This <br />commitment has not been met. Included in the approximately 430 acres is the <br />West Pit overburden stockpile (Hink's Peak) which contains more than 3 <br />million yards of overburden that must be returned to the West Pit. Since <br />Colowyo is behind with the 2007 spoil grading commitment the Division is