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MINOR REVISION NO. 43 <br />As evidence of its intent to transition the Keenesburg Mine, from a surface coal mining <br />operation to a reclamation site, Coors Energy Company (CEC) submitted, and received <br />approval for Technical Revision No. 20 (2/27/89). This technical revision allowed for a <br />variance from contemporaneous reclamation of the Keenesburg Mine for an initial period <br />of five years. It also acknowledged CEC's plans for the backfilling of A-Pit, for the <br />remediation of two irrigation sumps, and for the further fill work necessary to finish the <br />reclamation of B-Pit. What was not recognized in Technical Revision No. 20 was the <br />quantity of long-term spoil required to complete all of these reclamation tasks versus the <br />quantities of long-term spoil available at the Keenesburg Mine site. <br />When it submitted Minor Revision No. 24 (3/3/94), CEC sought approval for the <br />redesign of the remaining pits (A-Pit and B-Pit) to accept the disposal of ash from the <br />then Coors owned power plant in Golden, as part of the reclamation process. The <br />reclamation activities were to proceed in a manner that included both removal of coal <br />related facilities and reclamation of the two pit areas. Reclamation was to be <br />accomplished by the continuous filling of the two pits with ash, commensurate with the <br />availability of ash from the Golden power plant. When filled, the pits would be covered <br />with spoils and topsand, followed by the application of soil amendments and final <br />seeding. Consistent with this approach, additional five-year variances have been asked <br />for and approved as Minor Revisions 36 and 40. <br />With this submittal of Minor Revision No. 43, CEC is requesting a further extension of <br />the variance from the 180-day rule for contemporaneous reclamation. This request for <br />variance focuses only on the B-Pit area, since the A-Pit reclamation work was complete <br />by the end of 1999. Further, all of the specifically coal related facilities and equipment <br />have been salvaged, converted, or removed from the site. The single exception is a "blast <br />hole drill" which is being dismantled and salvaged as time allows. Finally, <br />Sedimentation Pond No. 2 and the perimeter ditches have been designated "permanent <br />features", and the roads once used to support mining operations are being removed and <br />reclaimed as quickly as the areas they previously accessed are themselves fully <br />reclaimed. <br />The remainder of B-Pit is designed and permitted for the disposal of ash and mine waste <br />rock (MR# 34, 08/98). CEC now estimates it will require another approximately 797,240 <br />banked cubic yards of material (ash or mine waste rock) to codiplete the reclamation <br />process. [This number is consistent with MR# 40 but at variance with the MR# 36 <br />submittal. A review of the Annual Hydrology and Reclamation Reports, for the years <br />1999 through 2003 confirms the orderly, consistent progression of the fill activity.] At <br />the present rate of ash generation for disposal, the reclamation of B-pit is forecast to <br />require an additional ten + years. Based on the information presented, CEC requests the <br />Division's approval of this Minor Revision No. 43, to further extend the variance from <br />the 180-day rule for contemporaneous reclamation, and for an additional five-year period, <br />commencing March 3, 2009.