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C1982056, RN5, Adequacy Review 3 1/16/2009 <br />the permit in agreement with officers and director information in the national AVS database. <br />(Rule 2.03.4). <br />7. Section 2.05, p. 105.1 includes a discussion of reclamation of the NMD site; dismantling of the <br />surface facilities, removal of powerline, transformers, structure, regrading the pad and road, but <br />there is no discussion regarding sealing the boreholes. Please direct the Division to where <br />sealing of the NMD power boreholes is discussed in the PAP, or include a discussion of sealing <br />these NMD boreholes. (Rule 4.07.3). <br />8. Section 2.05, p. 105. 1, in the discussion of the NW-Mains Vent Shaft reclamation, reclamation <br />of the Thickener Underflow Project is included in the last paragraph (TR-39). This seems an <br />obscure place to add this description. For the sake of organization, and finding appropriate <br />descriptions regarding reclamation of facilities, this description would be better placed with <br />description of the Portal Area reclamation (p. 2.05-99 or 2.05-100). The current location of the <br />Thickener Underflow reclamation is incorporated with facilities that are remote from the main <br />facilities area. Since the Thickener Underflow lines are located at the main facilities, <br />reorganizing the description would be logical. <br />9. Page 2.05-106 contains text that discusses the 6-Main North Ventilation Shaft and Facilities. <br />This page has been revised on 1/7/2008 (MR227, approved 1/11/2008), 2/4/2008 (TR62, <br />approved 2/4/2008), and 8/1/2008 (MR229, approved 8/22/2008). It appears that text approved <br />in MR227 and TR62 was lost from this page with the approval of MR229. Please replace the <br />previously approved text or if the approved text has been moved to another page, please direct <br />the Division to its location. <br />10. Rangeland seed mix, Table 55 and text on page 2.05-112 discuss seeding techniques to be <br />utilized for the reclaimed areas. The discussion in the text references studies from the 1970's <br />and older. While the results of these studies are valid, observation of thirty years or more of <br />reclaimed coal mines in Northwest Colorado have resulted in planting techniques that help with <br />establishment of diverse permanent plant communities on reclaimed lands. The Division <br />conducted a shrub establishment study in conjunction with Colorado State University, <br />Department of Range Science, and three coal mine operators in Northwest Colorado. The study <br />recognized the difficulties a number of operators were having establishing shrub species using <br />traditional reclamation methods. The study initiated in 2000, eight years of observations have <br />provided the Division, CSU and coal mine operators valuable results regarding seeding <br />techniques that have favorable shrub establishment. <br />The current rangeland seed mix (Table 55) and seeding method (P. 2.05-112) in the Foidel <br />Creek permit is expected to encounter similar difficulties experienced at other locations in <br />Northwest Colorado based upon the similarities in seed mix, environment, and seeding <br />techniques. The Division suggests re-evaluation of the seed mix and planting methods for the <br />rangeland areas incorporating some of the more recent study findings to assist in successful re- <br />establishment of a diverse rangeland community that will achieve Foidel Creek Mine's <br />reclamation success standards.