2008-03-14_REVISION - C1981038

• Permit No: C1981038
• IBM Index Class Name: REVISION
• Doc Date: 3/14/2008
• Doc Name: Review Letter ‎(Internal Memo)‎
• From: Dan Mathews
• To: Joe Dudash
• Type & Sequence: TR48
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]

COLORADO
D I V I S I ON OF
RECLAMATION
MINING
SAFETY
DRMS INTERNAL MEMORANDUM
DATE: March 14, 2008
TO: Joe Dudash
FROM: Dan Mathews
RE: Bowie No. 1 Mine (Permit No. C-1981-038)
TR-48 (Reclamation Plan Revisions)
Bill Ritter, Jr.
Governor
Harris D. Sherman
Executive Director
Ronald W. Cattany
Division Director
Natural Resource Trustee
Joe, pursuant to your request, I have reviewed the revegetation related changes proposed in TR-48,
including the plan to eliminate fertilizer application and to employ extensive roughening on
predominantly south and west facing slopes. Because of my lack of familiarity with the site and the
permit, I took a fair amount of time looking through the soils, vegetation, and revegetation sections
of the permit volumes and findings, to try to get a decent grasp of the situation out there.
What I have gleaned, is that the operation is inactive with no plans for future coal extraction, and
that there are portal benches, roads, areas at the loadout, and associated support facilities that have
not yet been reclaimed, but are to be reclaimed in the near future. Information indicates that
portions of the area were disturbed "pre-law" (East Mine and Loadout). For those areas, no topsoil
was salvaged and for the most part, topsoil would not be replaced at those sites.
The West Mine was apparently disturbed "Post-Law", and topsoil was salvaged and stockpiled,
with some areas previously reclaimed. I have not located a detailed accounting of areas to be
topsoiled, with average replacement thickness specification for each delineated area, but my
understanding is that all West Mine areas would be topsoiled, with average topsoil thickness to vary
from 8 inches to 24 inches, depending on location.
At the Paonia Loadout, approximately 40 acres were disturbed, with no topsoil salvage. The area is
a "grand-fathered" alluvial valley floor, and topsoil was not salvaged prior to disturbance. The
AVF was flood irrigated cropland (apparently fruit orchard) prior to disturbance and the
predominant soil type was Aqua Fria stony loam, which NRCS has identified as a soil type that
supports "Farmland of Statewide Importance". There are a couple different revegetation plans
described in the permit application (orchard reestablishment or grass hay cropland establishment);
neither plan is very detailed and success standards for either scenario are pretty nebulous. The grass
hay cropland plan seems to have been inserted into the permit subsequent to the original orchard
reestablishment plan, but the orchard reestablishment plan is still referenced in the current renewal
findings document. I think it may be necessary for the operator to submit a separate technical
revision application plan to clarify the proposed loadout revegetation plan, eliminate outdated
information, and provide additional detail regarding soil reconstruction, liability period crop
management, and success criteria.
Office of Office of
Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines