2009-10-22_REPORT - C1981028 (3)

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INTEROFFICE MEMORANDUM TO: KEENESB4FICI FROM: JAN ET BISUBJECT: KEENESB REC[.AMATION REPORTS DATE: 10/22/2009 Coors Energy Company submitted the 2008 ARR on February 26, 2009. The Keenesburg Mine permit, 0-1981- 028, page 117, has committed to submitting the Annual Reclamation Report by the end of February each year. The submitted report is in compliance with the approved permit. Vegetative success is based on comparison with an approved formula standard that is based on growing season precipitation (PAP page 116b). Cover success is based on total vegetative cover. Production is based on herbaceous vegetative cover. Species composition is based on relative cover of the individual plant species compared to a composition standard. There is no woody stem density requirement for the Keenesburg Mine reclamation success standard. Coors Energy Company (CEQ did not conduct vegetation sampling in 2008 due to an unusually dry growing season. On August 14, 2008, CEC notified the Division requesting a variance from the annual vegetation sampling at the Keenesburg Mine. The Division concurred with CEC's request on August 19, 2009. C'EC conducted pest and disease inspection of the reclaimed area on March 14, 2008, June 8, 2008, August 11, 2008, and November 19, 2008. The result of the pest and disease inspection found no noxious weed infestations or blight of the re-established vegetation. Observations were made on August 11, 2008 of the stunted nature of the vegetation due to the lack of moisture during the growing season. Precipitation record for 2008 totaled 14.37 inches. However, the total precipitation that fell in May, June and July 2008, which represents the majority of the growing season totaled 3.96 inches. Heavy rains occurred in August, but by that point in the growing season, plants were rather stunted and many had already produced seed. No new areas were disturbed by CEC operations in 2008. CEC continued to place ash, spoil cover, and placed topsoil (topsand) on reclamation parcel 31P. Parcel 31P was still undergoing reclamation activities at the end of 2008, and had not been seeded with either the sorghum cover crop or the permanent seed mix, so CEC did not count this parcel in "reclaimed or revegetated" totals for 2008. No new areas were seeded in 2008. CEC reports that in 2008, the Keenesburg mine had a total of 438+/- (acres rounded to nearest whole number) disturbed acres. Of the 438 disturbed acres, 251+/- (rounded to nearest whole number) acres had been backfilled and graded. CEC replaced topsoil (topsand) on 12+/- acres in 2008, bringing the total topsoiled acreage to 251 +/- acres. CEC has previously seeded 239+/- acres with the permanent seed mix. These acreage values agree with values reported in 2007 by CECw The DRMS database reports the disturbed acreage as 439.0 acres. CEC submits results of ash disposal with the Annual Reclamation Report. The volume of ash placed in the disposal area, and the results on chemical analysis sample of bottom ash and flyash are included with the report. In 2008, CEC reports that 46,897 tons of mixed flyash and bottom ash were disposed of in the B Pit at the Keenesburg Strip Mine. Two samples, one flyash sample and one bottom ash sample, were analyzed for TCLP metals (leached), and TCLP mercury (leached). Results of the bottom ash sample recorded Barium at 2.1 mg/L. The lowest quantitation limit reported by the laboratory is 2 for barium using this method, and the regulatory action limit for Barium is 100 mg/L. The measured value for Barium for the bottom ash sample is very low and